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

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
Creator
Subject
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
Instantiates
Publication
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
Publication

Library Locations

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      52.3736660 4.9336932
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