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The Resource Taxation of branches of international banks : towards a multilateral tax treaty

Taxation of branches of international banks : towards a multilateral tax treaty

Label
Taxation of branches of international banks : towards a multilateral tax treaty
Title
Taxation of branches of international banks : towards a multilateral tax treaty
Creator
Subject
Language
eng
Summary
Dissertation, published in 2003 at the Deakin University, examining the OECD rules for the allocation of business profits to branches of international banks under Article 7 of the OECD Model and Commentary. The author establishes two prepositions in making its case for reform of the international tax system. The first is that bilateral tax treaties are inappropriate instruments to use for allocating taxing rights over international banks operating through branches. The second proposition is that the arm's length principle is an ineffective measure to use for allocating business profits to branches of international banks because it does not reflect business reality. The thesis suggests that a multilateral tax treaty using formulary apportionment, is a more effective method to use for allocating business profits to branches of international banks, which corresponds more closely with economic reality than the arm's length method
http://library.link/vocab/creatorName
Kobetsky, M
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
http://library.link/vocab/subjectName
  • OECD Model
  • allocation of profits
  • branch
  • banking
Label
Taxation of branches of international banks : towards a multilateral tax treaty
Instantiates
Publication
Extent
X, 283 p.
Isbn
9789070125578
Label
Taxation of branches of international banks : towards a multilateral tax treaty
Publication
Extent
X, 283 p.
Isbn
9789070125578

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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