The Resource OECD discussion around the definition of permanent establishments : a German view on proposed amendments to the Model Commentary and their effect on business profit allocation and international assignments

OECD discussion around the definition of permanent establishments : a German view on proposed amendments to the Model Commentary and their effect on business profit allocation and international assignments

Label
OECD discussion around the definition of permanent establishments : a German view on proposed amendments to the Model Commentary and their effect on business profit allocation and international assignments
Title
OECD discussion around the definition of permanent establishments : a German view on proposed amendments to the Model Commentary and their effect on business profit allocation and international assignments
Creator
Subject
Language
eng
Summary
Within the system of double taxation treaties the concept of permanent establishments constitutes the predominant link to tie revenue to a source state. It is not only of importance for allocation of business profits and the taxation rights accrued thereupon, but can also determine which cntracting state is allowed to levy taxes on employee remuneration in case of certain short-term assignments. In addition it decides about certain corporate tax consequences secondment activities may have. Understanding and interpretation of the concept are under current discussion on OECD level. This article sums up the debate's main aspects, presents its consequences and explains why Germany has a reserved position towards some of the henceforth proposed changes
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 40 (2012),
http://library.link/vocab/creatorName
  • Hilbert, L
  • Engel, B
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • OECD Model
  • PE
  • allocation of taxing rights
  • business profits
  • employment income
  • joint venture
  • partnership
  • place of effective management
  • construction project
  • agency PE
Label
OECD discussion around the definition of permanent establishments : a German view on proposed amendments to the Model Commentary and their effect on business profit allocation and international assignments
Instantiates
Publication
Label
OECD discussion around the definition of permanent establishments : a German view on proposed amendments to the Model Commentary and their effect on business profit allocation and international assignments
Publication

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