Triangular Situation: Partnership with Sub-Permanent Establishment in Third Countries
Facts: A German partnership (transparent according to German tax law, treated as a permanent establishment according to Art. 5 OECD Model in Germany) operates construction projects in Switzerland and in the UK that last 13 (or 11) months. The partners of the German partnership are residents of Austria.
Aufsatz von Michael Lang, Helmut Loukota, Robert Waldburger, Mike Waters und Ulrich Wolff, SWI 1/2004, 14