Gewinnabgrenzung nach dem Authorised OECD Approach (AOA)

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The item Gewinnabgrenzung nach dem Authorised OECD Approach (AOA) represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: The Authorized OECD Approach (AOA) standardizes an unrestricted fiction of independence for the profit allocation between parent company and permanent establishment. This leads to a fundamental and extremely practice-relevant change in the international definition of profits of permanent establishments. The constant expansion of the concept of permanent establishments by the OECD also ensures that more and more planned and unplanned permanent establishments are created. As a result, the number of planned and unplanned permanent establishments is increasing. This book provides a solution-oriented analysis of the legal framework and the individual regulations of the AOA - the German Federal Law on the Establishment of Business Combinations. The complex subject matter of the AOA is fully explored: explanation of the undefined legal terms and the normative framework from the perspective of the OECD as well as European Union and national law, allocation of profits according to the AOA in detail, e.g. assumed relationships under the law of obligations, assets, endowment capital, personnel functions, relocation of functions, representative offices, documentation, auxiliary invoices and auxiliary invoices, AOA and industry specific characteristics: mechanical and plant engineering, bank premises, insurance companies, production facilities and finally, the application of AOA in selected countries in Europe, Asia, Africa, the Middle East, North America and South America

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Summary: The Authorized OECD Approach (AOA) standardizes an unrestricted fiction of independence for the profit allocation between parent company and permanent establishment. This leads to a fundamental and extremely practice-relevant change in the international definition of profits of permanent establishments. The constant expansion of the concept of permanent establishments by the OECD also ensures that more and more planned and unplanned permanent establishments are created. As a result, the number of planned and unplanned permanent establishments is increasing. This book provides a solution-oriented analysis of the legal framework and the individual regulations of the AOA - the German Federal Law on the Establishment of Business Combinations. The complex subject matter of the AOA is fully explored: explanation of the undefined legal terms and the normative framework from the perspective of the OECD as well as European Union and national law, allocation of profits according to the AOA in detail, e.g. assumed relationships under the law of obligations, assets, endowment capital, personnel functions, relocation of functions, representative offices, documentation, auxiliary invoices and auxiliary invoices, AOA and industry specific characteristics: mechanical and plant engineering, bank premises, insurance companies, production facilities and finally, the application of AOA in selected countries in Europe, Asia, Africa, the Middle East, North America and South America

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