Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention

Resource Information

The work Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention 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

Permanent establishment through related persons : a study on the treatment of related persons under Article 5 of the OECD Model Tax Convention

Creator

• Jacobsson, L

Subject

• OECD Model
• PE
• associated enterprises
• auxiliary activities
• BEPS
• fixed place of business
• international tax law
• tax treaty
• connected person

Language

eng

Summary

This thesis deals with related persons and the permanent establishment (PE) concept, and the increasing tension between them. The main objective of the thesis is to analyse and define the scope of the PE concept, when applied to related persons. To meet this objective, the thesis is focused on three research questions. Initially, a theoretical foundation regarding the PE concept is established. It is concluded that the PE concept's underlying principles are the notions of source, equity and basic neutrality. The first research question deals with the scope of the "related company clause" in Article 5(7) of the OECD MTC. The second research question deals with the application of the PE concept to situations with related persons. The third research question considers what function the PE concept has, or should have, when it comes to preventing tax avoidance

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction