The Resource Transfer of assets regime applicable to US company's PE under tax treaty non-discrimination rule

Transfer of assets regime applicable to US company's PE under tax treaty non-discrimination rule

Label
Transfer of assets regime applicable to US company's PE under tax treaty non-discrimination rule
Title
Transfer of assets regime applicable to US company's PE under tax treaty non-discrimination rule
Creator
Subject
Language
eng
Summary
This note examines the Supreme Administrative Court's decision in KHO 2013:169 (25 October 2013), wherein a US resident company claimed that the Finnish transfer of assets rules resulted in prohibited discrimination of its Finnish permanent establishment under the Finland-United States Income and Capital Tax Treaty (1989)
Citation source
In: European taxation. - Amsterdam. - Vol. 54 (2014),
http://library.link/vocab/creatorName
Nieminen, M
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • OECD Model Commentaries
  • case law
  • transfer of assets
  • PE
  • tax treaty
  • losses
Label
Transfer of assets regime applicable to US company's PE under tax treaty non-discrimination rule
Instantiates
Publication
Label
Transfer of assets regime applicable to US company's PE under tax treaty non-discrimination rule
Publication

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