Taxation of cross-border services

Resource Information

The work Taxation of cross-border services represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Taxation of cross-border services

Creator

• Taxation of cross-border services
• Rawal, R

Subject

• PE
• UN Model
• domestic tax law
• effectively connected income
• fixed base
• independent personal services
• service fee
• services
• services PE
• source of income
• tax avoidance
• tax treaty
• technical services
• OECD Model

Language

eng

Summary

In many countries today cross-border trade in services exceeds cross-border trade in goods. As a result there has been an urgent call, from supranational institutions as well as from jurisdictions around the world, for corresponding changes in tax treaties and domestic tax law rules to counteract new forms of legal uncertainty, especially major developments in tax avoidance strategies. Building on a detailed analysis of the OECD and the UN tax treaty models as regards taxation of cross-border services, this book responds to several questions: Can rendition of services result in a permanent establishment in the receiving country? What are the provisions for service PEs in the UN and OECD models and commentary? What is the distinction between 'fees' and 'fees for technical services'? How do the articles dealing with 'fees for technical services', 'PE', and 'independant personal services' interact with each other?

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction

Series statement

Series on international taxation

Series volume

47