The Resource The definition of permanent establishment : current OECD and German case law developments

The definition of permanent establishment : current OECD and German case law developments

Label
The definition of permanent establishment : current OECD and German case law developments
Title
The definition of permanent establishment : current OECD and German case law developments
Creator
Subject
Language
eng
Summary
Article 5 of the OECD Model Tax Convention (MTC) settles the definition of the treaty concept of permanent establishments. Although in the past Article 5 has remained untouched, the commentary on the OECD MTC has several times been adjusted on the changing forms of international business, constantly lowering the bar for what constitutes a permanent establishment. Furthermore recent rulings of Germany's Federal Finance Court illustrate, that the court also seems to sympathize with an increasingly broader understanding. Since the practical application of Article 5 raises a number of questions, the OECD has released a public discussion draft listing proposals for changes to the 2014 update of the commentary on Article 5. The authors give an overview of the proposed changes as well as on recent rulings of the German Federal Finance Court addressing the requirements needed to constitute a permanent establishment
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 40 (2012),
http://library.link/vocab/creatorName
  • Ditz, X
  • Quilitzsch, C
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • OECD Model
  • PE
  • case law
Label
The definition of permanent establishment : current OECD and German case law developments
Instantiates
Publication
Label
The definition of permanent establishment : current OECD and German case law developments
Publication

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      52.37366609999999 4.9336932
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