Ibid. Figure № 2. A typical VC fund structure. P. 10.
1189
Emidio Cacciapuoti. Private Equity Funds, Permanent Establishments and Italian Operations. IBFD. European Taxation. 2007. № 4. P. 169.
1190
Report of Expert Group on Removing Tax Obstacles to Cross-border Venture Capital Investments. P. 18.
1191
Ibid.
1192
Revised Proposals Concerning The Interpretation and Application of Article 5 (Permanent Establishment) of the Model Tax Convention (19 October 2012 to 31 January 2013). OECD. § 23. P. 38–41.
