The Resource Allocation of head office expenses and the interpretation of article 7(3) of the United Nations Model Tax Treaty

Allocation of head office expenses and the interpretation of article 7(3) of the United Nations Model Tax Treaty

Label
Allocation of head office expenses and the interpretation of article 7(3) of the United Nations Model Tax Treaty
Title
Allocation of head office expenses and the interpretation of article 7(3) of the United Nations Model Tax Treaty
Creator
Subject
Language
eng
Summary
In this article, the author discusses the interpretation of article 7(3) of the UN Model Tax Treaty and the allocation of head office expenses to a permanent establishment under Indonesia's domestic law. The article reviews Indonesian case law, which has generally upheld the indirect method of allocation, despite double taxation outcomes, and supported the tax authority's demands for detailed supplementary information and documentation beyond consolidated accounts and audited allocation methodologies. The author also addresses arm's length pricing of intra-group services and suggests that it might be challenged by the Indonesian tax authority in the determination of taxable profit of a permanent establishment in Indonesia
Citation source
In: Asia-Pacific tax bulletin. - Amsterdam. - Vol. 24 (2018), no. 5 ; 8 p
http://library.link/vocab/creatorName
Adoe, A
Geographic coverage
Asia
Language note
English
http://library.link/vocab/subjectName
  • case law
  • UN Model
  • head office expenses
  • PE
  • allocation of expenses
  • intra-group services
Label
Allocation of head office expenses and the interpretation of article 7(3) of the United Nations Model Tax Treaty
Instantiates
Publication
Label
Allocation of head office expenses and the interpretation of article 7(3) of the United Nations Model Tax Treaty
Publication

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