The Resource Status of implementation of the authorized OECD approach into domestic tax law and tax treaties - part 2

Status of implementation of the authorized OECD approach into domestic tax law and tax treaties - part 2

Label
Status of implementation of the authorized OECD approach into domestic tax law and tax treaties - part 2
Title
Status of implementation of the authorized OECD approach into domestic tax law and tax treaties - part 2
Creator
Subject
Language
eng
Summary
This article examines profit/loss allocation in a headquarter/branch scenario. Part 1, which was published in European Taxation 8 (2015), discussed the actual split between a head office and branch from a theoretical perspective, basic concepts derived from public international treaty law, the notion of Key Entrepreneurial Risk-Taking Functions versus Significant People Functions and the Authorised OECD Approach (AOA). Part 2 continues to analyse the AOA, looks at the question of whether adequate capital is allocated to the branch as a fictitious separate entity and outlines court cases, tax policy and advance pricing agreement/mutual agreement procedure implications
Citation source
In: European taxation. - Amsterdam. - Vol. 55 (2015),
http://library.link/vocab/creatorName
  • Huibregtse, S.B
  • Verdoner, L.A
  • Valutyte, I
  • Offermanns, R.H.M.J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • AOA
  • head office
  • branch
  • PE
  • allocation of profits
  • double taxation
  • tax treaty
Label
Status of implementation of the authorized OECD approach into domestic tax law and tax treaties - part 2
Instantiates
Publication
Label
Status of implementation of the authorized OECD approach into domestic tax law and tax treaties - part 2
Publication

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