The Resource Lowering the permanent establishment threshold via the anti-BEPS convention : much ado about nothing?

Lowering the permanent establishment threshold via the anti-BEPS convention : much ado about nothing?

Label
Lowering the permanent establishment threshold via the anti-BEPS convention : much ado about nothing?
Title
Lowering the permanent establishment threshold via the anti-BEPS convention : much ado about nothing?
Creator
Subject
Language
eng
Summary
The author examines the lowering of the threshold at which commissionaire, auxiliary, and building site and construction activities qualify as a permanent establishment under the Multilateral anti-BEPS Convention (MLI). With a view to countries planning to implement the provisions in this convention on permanent establishments within their tax treaty networks, the author argues for exercising a degree of caution. Some caution may be worthwhile to be exercised specifically with regard to the MLI provisions on commissionaire and auxiliary activities, as these provisions seem unlikely to have any substantial effect in terms of effectively shifting substantial tax base towards market jurisdictions
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 45 (2017), no. 8/9 ; p. 556-566
http://library.link/vocab/creatorName
Wilde, M.F. de
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • PE
  • commissionaire
  • auxiliary company
  • construction project
  • MLI
Label
Lowering the permanent establishment threshold via the anti-BEPS convention : much ado about nothing?
Instantiates
Publication
Label
Lowering the permanent establishment threshold via the anti-BEPS convention : much ado about nothing?
Publication

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