Publications by Dr R.L. Williams

Fundamentals of Permanent Establishments by Lee Williams

Fundamentals of Permanent Establishments (Second Edition)


The permanent establishment (PE) concept is a threshold issue which must be confronted and addressed by virtually every enterprise seeking to conduct trading activities in one or more countries other than its home country. Whether or not an enterprise has a ‘permanent establishment’ in a country defines whether its trading income can be taxed or is exempt under a network of over 1,000 bilateral income tax treaties and some local laws. Today, the interaction of rapidly changing rules, increased enforcement, and evolving business operations creates a challenging environment for tax directors of global businesses who must understand and manage their company’s PE risks.

This updated and expanded second edition of a concise guide that has been a key reference for decades – formerly titled Permanent Establishments: A Planning Primer – provides lucid insight into business structuring and the related tax considerations. Completely updated and expanded, it remains the only practical introductory book on PE available. It covers all important aspects of fixed place of business and dependent agency types of permanent establishment, as well as the exceptions for independent agents, permitted ancillary activities, and parent–subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions.
Notable features of the new edition include the following:
  • entirely new chapters on e-commerce, supply chain and contract manufacturing structures, and service PEs;
  • thorough updating of model treaty changes and PE rulings globally; and
  • impact of new developments in mineral extraction, real estate leasing, and construction management.
The second edition identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries. The text integrates conceptual analyses and technical discussion with relevant tax planning considerations, appropriately highlighted or diagrammed. Concisely written, easily readable and topically organized for quick reference, this book will be of interest to all international tax planners, lawyers, accountants, multinational CFOs, executives and others whose role involves the structure and operations of international trading or commercial presence.

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Williams on Permanent Establishments

Williams on Permanent Establishments


"This book is a comprehensive review of the tax treaty concept of a 'permanent establishment' from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries.

The book extensively deals with all aspects of the 'fixed place of business' and 'dependent agency' permanent establishments and the exceptions for independent agents, permitted ancillary activities and parent subsidiary relationships.

The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature. "
Aspen Publishers

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Williams on Permanent Establishments
Guide to US/UK Private Wealth Tax Planning

Williams on US / UK Private Wealth Tax Planning


"Explaining the estate and trust planning tax rules on one side of the Atlantic to advisers on the other, lucidly but accurately, is often the hardest task faced by those of us who advise the vast number of clients subject to both US and UK tax (who may be expats, Brits married to US citizens or vice versa, investors, or have extended families including residents in both countries). Lee Williams, Rick Layman and Dawn Nicholson have done just that in Butterworth’s Guide to US/UK Private Wealth Tax Planning.
This is not just an update of their much admired 1992 BNA leaflet US/UK Integrated Tax Planning: Estates, Gifts and Trusts, but a wholly new and substantial tome. Increased in scope and current through September 2004 – the relevant tax laws have changed substantially since 1992 and continue to do so – the book also includes many practical suggestions and planning ideas."
Bloomsbury Professional Book Review

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Williams on US/UK Private Wealth Tax Planning

Dr. Robert L Williams, BA, JD, LLM(Tax), TEP
La Fallue, Faldouet, St Martin, Jersey, Channel Islands, JE3 6DU
Tel: 00 44 (0)1534 853221