The Resource The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments
The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments
Resource Information
The item The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- This current note discusses the lack of support for the Authorised OECD Approach (AOA) to the attribution of profits to permanent establishments (PEs), and suggests a possible alternative based on the 1933 League of Nations' draft Convention on the Allocation of Business Income Between States. It reviews the Convention's policy on the relationship between separate but associated companies, and how its three approaches to attribution of profits to PEs could be developed
- Language
- eng
- Label
- The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments
- Title
- The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments
- Language
- eng
- Summary
- This current note discusses the lack of support for the Authorised OECD Approach (AOA) to the attribution of profits to permanent establishments (PEs), and suggests a possible alternative based on the 1933 League of Nations' draft Convention on the Allocation of Business Income Between States. It reviews the Convention's policy on the relationship between separate but associated companies, and how its three approaches to attribution of profits to PEs could be developed
- Citation source
- In: British tax review. - London. - (2018), no. 5 ; p. 514-520
- http://library.link/vocab/creatorName
- Baker, P
- Geographic coverage
-
- European Union
- Europe
- Language note
- English
- http://library.link/vocab/subjectName
-
- UN
- OECD Model
- allocation of income
- business profits
- allocation of profits
- PE
- AOA
- associated companies
- tax treaty
- Label
- The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments
- Label
- The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/The-League-of-Nations-Draft-Convention-for-the/Y23CdbOmbWo/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/The-League-of-Nations-Draft-Convention-for-the/Y23CdbOmbWo/">The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/The-League-of-Nations-Draft-Convention-for-the/Y23CdbOmbWo/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/The-League-of-Nations-Draft-Convention-for-the/Y23CdbOmbWo/">The League of Nations' Draft Convention for the Allocation of Business Income between States - a new starting point for the attribution of profits to permanent establishments</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
