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The Resource Cross-border taxation of permanent establishments : an international comparison

Cross-border taxation of permanent establishments : an international comparison

Label
Cross-border taxation of permanent establishments : an international comparison
Title
Cross-border taxation of permanent establishments : an international comparison
Creator
Subject
Language
eng
Summary
The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE definition and the allocation of profits between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this book illustrates and compares the OECD Model Tax Convention (OECD MC) with country-specific source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-specific PE concepts, the author's treatment covers such issues and topics as the following: the PE definition of the OECD MC and from the perspective of selected countries; allocation of business profits under the Authorised OECD Approach (AOA); avoidance of PE status; implementation of a service PE proposal; construction site PEs established by subcontractors; existence of an agency PE; and the OECD project on Base Erosion and Profit Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualification conflicts, thus reinforcing his detailed discussion of source taxation rules of business profits and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE
http://library.link/vocab/creatorName
Waltrich, A
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
Series on International Taxation
Series volume
59
http://library.link/vocab/subjectName
  • OECD Model
  • PE
  • allocation of profits
  • source principle of taxation
  • AOA
  • nexus
  • construction project
  • agency PE
  • BEPS
  • tax treaty
  • case law
Label
Cross-border taxation of permanent establishments : an international comparison
Instantiates
Publication
Extent
xxiii, 328 p.
Isbn
9789041168320
Label
Cross-border taxation of permanent establishments : an international comparison
Publication
Extent
xxiii, 328 p.
Isbn
9789041168320

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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