عنوان مقاله [English]
The legal characterisation of cross-border oil and gas pipelines remains controversial. It can be said these pipelines shall be considered as “Permanent Establishments” of the oil and gas companies. These pipelines might also be characterised as immovable properties the income of which shall be subject to the rules governing taxation of immovable properties. Pursuant to another view, it can be claimed that oil and gas pipelines only have a facilitating role as they only transport oil and gas products. Thus, it could be discussed that compared to the main activities of oil and gas companies, this facilitating role is of non-central importance for these companies. The adoption of each approach has different financial implications for the companies. This article seeks to put forward some solutions for reducing the ambiguities surrounding the topic and to resolve the conflicts of laws in respect to the characterisation of cross-border oil and gas pipelines.
(تاریخ آخرین بازدید: ۱ مهر ۱۴۰۰)
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