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The Resource Taxation of business profits in the 21st century : selected issues under tax treaties

Taxation of business profits in the 21st century : selected issues under tax treaties

Label
Taxation of business profits in the 21st century : selected issues under tax treaties
Title
Taxation of business profits in the 21st century : selected issues under tax treaties
Contributor
Subject
Language
eng
Summary
The taxation of business profits derived from cross-border activities is one of the core issues in international tax law. The key principle for the allocation of taxing rights between countries is laid down in article 7 of the OECD Model, which states that profits of a resident enterprise of a state shall be taxable only in that state unless the enterprise carries on business in another state through a permanent establishment situated therein. In the latter case, the profits that are attributable to the permanent establishment may be taxed in that other state. The determination of the source state's taxing rights basically requires two steps. First, it must be determined whether or not there is a permanent establishment in that state, as defined by article 5 of the OECD Model, and second, the profits attributable to that permanent establishment must be ascertained. This book sheds light on a selection of issues surrounding the essential questions described above from a practical as well as from an academic perspective. The first part is dedicated to issues relating to the application of article 5 of the OECD Model and the problem of determining the existence of a permanent establishment in a state. The second part of the book relates to issues arising from article 7 of the OECD Model and the attribution of profits to a permanent establishment
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
http://library.link/vocab/relatedWorkOrContributorName
  • Gutiérrez Puente, C
  • Perdelwitz, A
Series statement
[IBFD Tax Research Series
Series volume
volume 1]
http://library.link/vocab/subjectName
  • OECD Model
  • allocation of taxing rights
  • business income
  • tax treaty
  • PE
  • agency PE
  • withholding tax
  • services
  • telecommunication industry
  • intangibles
  • AOA
  • case law
  • UN Model
Label
Taxation of business profits in the 21st century : selected issues under tax treaties
Instantiates
Publication
Contents
  • At the disposal of - the way towards a broader concept
  • Popa, O.
  • ; p. 3-26
  • A certain degree of permanence - between temporary and everlasting business activities
  • Perdelwitz, A.
  • ; p. 27-55
  • In the name of clarity : defining a dependent agent permanent establishment
  • Obuoforibo, B.R.
  • ; p. 57-78
  • Withholding taxes on services income - a 21st century outlaw or a necessary evil?
  • Law, S.B.
  • ; p. 79-102
  • Controversies involving the taxation of cross-border telecommunication income : is there a need for new rules?
  • Cotrut, M.
  • ; p. 103-132
  • The authorized OECD approach : an overview
  • Bernales, R.
  • ; p. 135-181
  • Capital structure and financing of permanent estabishments
  • Nouel, L.
  • ; p. 183-208
  • Permanent establishments and intangibles : when did notional royalties become a reality?
  • Vlasceanu, R.
  • ; p. 209-229
  • How fiction becomes reality : equal treatment for permanent establishments and resident enterprises
  • Kulcsár, T.
  • ; p. 231-250
  • The applicability of the AOA to existing tax treaties - a matter of interpretation?
  • van Boeijen-Ostaszewska, O.
  • ; p. 251-272
  • Implementation of the authorized OECD approach by OECD member countries
  • Kosters, B.
  • Offermanns, R.
  • ; p. 273-306
  • The UN Model and the BRICS countries - another view
  • Gutiérrez, C.
  • ; p. 307-339
Extent
XXIV, 341 p.
Isbn
9789087221904
Isbn Type
(IBFD eBook)
Label
Taxation of business profits in the 21st century : selected issues under tax treaties
Publication
Contents
  • At the disposal of - the way towards a broader concept
  • Popa, O.
  • ; p. 3-26
  • A certain degree of permanence - between temporary and everlasting business activities
  • Perdelwitz, A.
  • ; p. 27-55
  • In the name of clarity : defining a dependent agent permanent establishment
  • Obuoforibo, B.R.
  • ; p. 57-78
  • Withholding taxes on services income - a 21st century outlaw or a necessary evil?
  • Law, S.B.
  • ; p. 79-102
  • Controversies involving the taxation of cross-border telecommunication income : is there a need for new rules?
  • Cotrut, M.
  • ; p. 103-132
  • The authorized OECD approach : an overview
  • Bernales, R.
  • ; p. 135-181
  • Capital structure and financing of permanent estabishments
  • Nouel, L.
  • ; p. 183-208
  • Permanent establishments and intangibles : when did notional royalties become a reality?
  • Vlasceanu, R.
  • ; p. 209-229
  • How fiction becomes reality : equal treatment for permanent establishments and resident enterprises
  • Kulcsár, T.
  • ; p. 231-250
  • The applicability of the AOA to existing tax treaties - a matter of interpretation?
  • van Boeijen-Ostaszewska, O.
  • ; p. 251-272
  • Implementation of the authorized OECD approach by OECD member countries
  • Kosters, B.
  • Offermanns, R.
  • ; p. 273-306
  • The UN Model and the BRICS countries - another view
  • Gutiérrez, C.
  • ; p. 307-339
Extent
XXIV, 341 p.
Isbn
9789087221904
Isbn Type
(IBFD eBook)

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