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Schedule 23: Meaning of permanent establishment
or “What counts as a fixed business location for tax purposes”

You could also call this:

“List of countries with special tax rules for international business income”

The International tax rules include a list of countries called the ‘grey list’. These countries are Australia (not including Norfolk Island), Canada, Germany, Japan, the United Kingdom, the United States (not including its territories), Norway, and Spain.

The rules also mention some special tax features that these countries have. For example, some countries might not tax money earned from business activities outside their borders. Australia and Canada have special rules for certain types of banks. Germany has special rules for investments in some areas, and the UK has special rules for ‘enterprise zones’.

Spain has special tax rules for activities in specific regions, including the Canary Islands, Ceuta, Melilla, and several other areas. These special rules might mean that businesses in these places pay less tax or get other benefits.

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Next up: Schedule 25: Foreign investment funds

or “Rules about overseas investments that are considered foreign investment funds”

24International tax rules: grey list countries

Part AGrey list countries

  • Australia, excluding the Territory of Norfolk Island
    1. Canada
      1. Federal Republic of Germany
        1. Japan
          1. United Kingdom of Great Britain and Northern Ireland
            1. United States of America, excluding its possessions and territories
              1. Norway
                1. Kingdom of Spain
                  1. Part BFeatures of the taxation law of countries specified in Part A

                  2. Any exemption from income tax for income derived from business activities carried on outside the country.
                    1. In the case of Australia, any special allowances, reliefs, or exemptions with respect to offshore banking units.
                      1. In the case of Canada, any special allowances, reliefs, or exemptions with respect to international banking centres.
                        1. In the case of the Federal Republic of Germany, any special allowances, reliefs, or exemptions with respect to regional located investment in the former German Democratic Republic or in West Berlin.
                          1. In the case of the United Kingdom of Great Britain and Northern Ireland, any special allowances, reliefs, or exemptions with respect to activities carried on in enterprise zones.
                            1. In the case of Canada, any special allowances, reliefs, or exemptions provided to non-resident owned investment corporations pursuant to section 133 of the Income Tax Act (Canada).
                              1. In the case of the Kingdom of Spain, any special allowances, reliefs, or exemptions with respect to activities that are carried on in, or by an enterprise registered in, the following:
                                1. Canary Islands:
                                  1. Ceuta:
                                    1. Melilla:
                                      1. Alava:
                                        1. Guipúzcoa:
                                          1. Vizcaya:
                                            1. Navarra.