The Resource Germany adopts new regulations governing allocation of income to permanent establishments

Germany adopts new regulations governing allocation of income to permanent establishments

Label
Germany adopts new regulations governing allocation of income to permanent establishments
Title
Germany adopts new regulations governing allocation of income to permanent establishments
Creator
Subject
Language
eng
Summary
As a result of the ordinance on the application of the arm's length principle to permanent establishments pursuant to section 1(5) of the German Foreign Tax Act (Betriebsstättengewinnaufteilungsverordnung, Ordinance on Income Allocation for Permanent Establishments) of 13 October 2014, income allocation for domestic and foreign permanent establishments stands on a new legal foundation. In particular, the new ordinance means that the 'Authorized OECD Approach (AOA)' with unlimited application of the separate enterprise fiction of permanent establishments for the purposes of income allocation is introduced into national law. The authors present the key principles of the ordinance and put forward a first critical appraisal
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 43 (2015),
http://library.link/vocab/creatorName
  • Ditz, X
  • Luckhaupt, H
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • allocation of income
  • PE
  • arm's length principle
  • AOA
  • accounting
  • tax treaty
Label
Germany adopts new regulations governing allocation of income to permanent establishments
Instantiates
Publication
Label
Germany adopts new regulations governing allocation of income to permanent establishments
Publication

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