The Resource The tax residence of companies

The tax residence of companies

Label
The tax residence of companies
Title
The tax residence of companies
Creator
Subject
Language
eng
Summary
This research paper, first, discusses the previous works of IFA on the subject and points out why corporate tax residence seems to be a good topic for the 2013 IFA Conference. Chapter 1 summarizes the current issues related to the tax residence of companies, the roots of the problems in connection with residence, the confusion on its meaning in relation to other criteria like domicile and nationality and the place of corporate tax residence within the legal system. Chapter 2 highlights the importance of corporate tax residence under domestic laws and DTCs and the different concepts of it in Model Tax Conventions. Chapter 3 pays attention to the problem of dual residence and focuses on the tie-breaker (the place of effective management, POEM) intended to resolve it in the OECD MTC. Finally, the development of the concept of POEM in the OECD Commentary, the impacts of modern technology on this tie-breaker and its possible future in light of the technical revolution of the 21st century are examined
http://library.link/vocab/creatorName
Kulcsár, T
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
IFA Research Paper
http://library.link/vocab/subjectName
  • OECD Model
  • residence
  • corporate income tax
  • dual residence
  • place of effective management
  • tie-breaker rule
Label
The tax residence of companies
Instantiates
Publication
Extent
38 p.
Label
The tax residence of companies
Publication
Extent
38 p.

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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