The Resource Taxation of large-scale construction projects and the OECD Discussion draft on the attribution of profits to a permanent establishment

Taxation of large-scale construction projects and the OECD Discussion draft on the attribution of profits to a permanent establishment

Label
Taxation of large-scale construction projects and the OECD Discussion draft on the attribution of profits to a permanent establishment
Title
Taxation of large-scale construction projects and the OECD Discussion draft on the attribution of profits to a permanent establishment
Creator
Subject
Language
eng
Summary
This article summarizes the concerns regarding the application of the profit allocation rules presented in the Draft to permanent establishments constituted by an enterprise as per art. 5, para. 3 of the OECD Model because of having a building site, construction or installation project lasting more than 12 months. It successively deals with: the functionally separate entity (FSE) approach and the plant construction industry; allocation of functions, assets and risks; hypothetical application of the arm's length principle; key entrepreneurial risk taking functions (KERT); combination of direct and indirect method in practice; and symmetrical application of the FSE approach
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 34 (2006),
http://library.link/vocab/creatorName
  • Bendlinger, S
  • Görl, M
  • Schon, C
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • construction project
  • PE
  • allocation of profits
  • key entrepreneurial risk-taking functions
Label
Taxation of large-scale construction projects and the OECD Discussion draft on the attribution of profits to a permanent establishment
Instantiates
Publication
Label
Taxation of large-scale construction projects and the OECD Discussion draft on the attribution of profits to a permanent establishment
Publication

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