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The Resource Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention

Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention

Label
Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention
Title
Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention
Creator
Subject
Language
eng
Summary
This thesis deals with related persons and the permanent establishment (PE) concept, and the increasing tension between them. The main objective of the thesis is to analyse and define the scope of the PE concept, when applied to related persons. To meet this objective, the thesis is focused on three research questions. Initially, a theoretical foundation regarding the PE concept is established. It is concluded that the PE concept's underlying principles are the notions of source, equity and basic neutrality. The first research question deals with the scope of the "related company clause" in Article 5(7) of the OECD MTC. The second research question deals with the application of the PE concept to situations with related persons. The third research question considers what function the PE concept has, or should have, when it comes to preventing tax avoidance
http://library.link/vocab/creatorName
Jacobsson, L
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
http://library.link/vocab/subjectName
  • OECD Model
  • PE
  • international tax law
  • tax treaty
  • connected person
  • associated enterprises
  • BEPS
  • fixed place of business
  • auxiliary activities
Label
Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention
Instantiates
Publication
Extent
355 p.
Isbn
9789150626865
Label
Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention
Publication
Extent
355 p.
Isbn
9789150626865

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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