The Resource Evaluate practicality of OECD PE activity exemptions in light of evolving tax nexus for consumer-facing business (OECD Model Convention, Article 5, paragraph 4)

Evaluate practicality of OECD PE activity exemptions in light of evolving tax nexus for consumer-facing business (OECD Model Convention, Article 5, paragraph 4)

Label
Evaluate practicality of OECD PE activity exemptions in light of evolving tax nexus for consumer-facing business (OECD Model Convention, Article 5, paragraph 4)
Title
Evaluate practicality of OECD PE activity exemptions in light of evolving tax nexus for consumer-facing business (OECD Model Convention, Article 5, paragraph 4)
Creator
Subject
Language
eng
Summary
This thesis analyses changes introduced by BEPS Action 7 for activity exemptions of Article 5.4 of the OECD Model Convention (MC). The use of activity exemptions is connected with taxation of return on fixed assets (routine profits) and allows taxpayers not to create a taxable presence in a host country. Taxation of return on digital assets (residual profits) has not been widely and openly discussed up until 2018 when the new nexus (Amount A) was introduced by the OECD as part of its Pillar 1 initiative. This thesis will also discuss how the underlying principles of the Amount A may affect the activity exemptions and what these principles might have in common with the new anti-fragmentation rule that is now part of Article 5.4
http://library.link/vocab/creatorName
Shachneva, E
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
http://library.link/vocab/subjectName
  • OECD
  • PE
  • OECD Model
  • nexus
  • auxiliary activities
  • BEPS Project (OECD)
  • MLI
  • Pillar 1 (OECD)
Label
Evaluate practicality of OECD PE activity exemptions in light of evolving tax nexus for consumer-facing business (OECD Model Convention, Article 5, paragraph 4)
Instantiates
Publication
Extent
42 p.
Label
Evaluate practicality of OECD PE activity exemptions in light of evolving tax nexus for consumer-facing business (OECD Model Convention, Article 5, paragraph 4)
Publication
Extent
42 p.

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