The Resource Taxation of business profits in the 21st century : selected issues under tax treaties
Taxation of business profits in the 21st century : selected issues under tax treaties
Resource Information
The item Taxation of business profits in the 21st century : selected issues under tax treaties represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 2 library branches.
Resource Information
The item Taxation of business profits in the 21st century : selected issues under tax treaties represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 2 library branches.
- Summary
- The taxation of business profits derived from cross-border activities is one of the core issues in international tax law. The key principle for the allocation of taxing rights between countries is laid down in article 7 of the OECD Model, which states that profits of a resident enterprise of a state shall be taxable only in that state unless the enterprise carries on business in another state through a permanent establishment situated therein. In the latter case, the profits that are attributable to the permanent establishment may be taxed in that other state. The determination of the source state's taxing rights basically requires two steps. First, it must be determined whether or not there is a permanent establishment in that state, as defined by article 5 of the OECD Model, and second, the profits attributable to that permanent establishment must be ascertained. This book sheds light on a selection of issues surrounding the essential questions described above from a practical as well as from an academic perspective. The first part is dedicated to issues relating to the application of article 5 of the OECD Model and the problem of determining the existence of a permanent establishment in a state. The second part of the book relates to issues arising from article 7 of the OECD Model and the attribution of profits to a permanent establishment
- Language
- eng
- Extent
- XXIV, 341 p.
- Contents
-
- At the disposal of - the way towards a broader concept
- Popa, O.
- ; p. 3-26
- A certain degree of permanence - between temporary and everlasting business activities
- Perdelwitz, A.
- ; p. 27-55
- In the name of clarity : defining a dependent agent permanent establishment
- Obuoforibo, B.R.
- ; p. 57-78
- Withholding taxes on services income - a 21st century outlaw or a necessary evil?
- Law, S.B.
- ; p. 79-102
- Controversies involving the taxation of cross-border telecommunication income : is there a need for new rules?
- Cotrut, M.
- ; p. 103-132
- The authorized OECD approach : an overview
- Bernales, R.
- ; p. 135-181
- Capital structure and financing of permanent estabishments
- Nouel, L.
- ; p. 183-208
- Permanent establishments and intangibles : when did notional royalties become a reality?
- Vlasceanu, R.
- ; p. 209-229
- How fiction becomes reality : equal treatment for permanent establishments and resident enterprises
- Kulcsár, T.
- ; p. 231-250
- The applicability of the AOA to existing tax treaties - a matter of interpretation?
- van Boeijen-Ostaszewska, O.
- ; p. 251-272
- Implementation of the authorized OECD approach by OECD member countries
- Kosters, B.
- Offermanns, R.
- ; p. 273-306
- The UN Model and the BRICS countries - another view
- Gutiérrez, C.
- ; p. 307-339
- Isbn
- 9789087221904
- Label
- Taxation of business profits in the 21st century : selected issues under tax treaties
- Title
- Taxation of business profits in the 21st century : selected issues under tax treaties
- Language
- eng
- Summary
- The taxation of business profits derived from cross-border activities is one of the core issues in international tax law. The key principle for the allocation of taxing rights between countries is laid down in article 7 of the OECD Model, which states that profits of a resident enterprise of a state shall be taxable only in that state unless the enterprise carries on business in another state through a permanent establishment situated therein. In the latter case, the profits that are attributable to the permanent establishment may be taxed in that other state. The determination of the source state's taxing rights basically requires two steps. First, it must be determined whether or not there is a permanent establishment in that state, as defined by article 5 of the OECD Model, and second, the profits attributable to that permanent establishment must be ascertained. This book sheds light on a selection of issues surrounding the essential questions described above from a practical as well as from an academic perspective. The first part is dedicated to issues relating to the application of article 5 of the OECD Model and the problem of determining the existence of a permanent establishment in a state. The second part of the book relates to issues arising from article 7 of the OECD Model and the attribution of profits to a permanent establishment
- Geographic coverage
- International
- Index
- no index present
- Language note
- English
- Literary form
- non fiction
- http://library.link/vocab/relatedWorkOrContributorName
-
- Gutiérrez Puente, C
- Perdelwitz, A
- Series statement
- IBFD Tax Research Series
- Series volume
- volume 1
- http://library.link/vocab/subjectName
-
- OECD Model
- allocation of taxing rights
- business profits
- tax treaty
- PE
- agency PE
- withholding tax
- services
- telecommunication industry
- intangibles
- AOA
- case law
- UN Model
- Label
- Taxation of business profits in the 21st century : selected issues under tax treaties
- Contents
-
- At the disposal of - the way towards a broader concept
- Popa, O.
- ; p. 3-26
- A certain degree of permanence - between temporary and everlasting business activities
- Perdelwitz, A.
- ; p. 27-55
- In the name of clarity : defining a dependent agent permanent establishment
- Obuoforibo, B.R.
- ; p. 57-78
- Withholding taxes on services income - a 21st century outlaw or a necessary evil?
- Law, S.B.
- ; p. 79-102
- Controversies involving the taxation of cross-border telecommunication income : is there a need for new rules?
- Cotrut, M.
- ; p. 103-132
- The authorized OECD approach : an overview
- Bernales, R.
- ; p. 135-181
- Capital structure and financing of permanent estabishments
- Nouel, L.
- ; p. 183-208
- Permanent establishments and intangibles : when did notional royalties become a reality?
- Vlasceanu, R.
- ; p. 209-229
- How fiction becomes reality : equal treatment for permanent establishments and resident enterprises
- Kulcsár, T.
- ; p. 231-250
- The applicability of the AOA to existing tax treaties - a matter of interpretation?
- van Boeijen-Ostaszewska, O.
- ; p. 251-272
- Implementation of the authorized OECD approach by OECD member countries
- Kosters, B.
- Offermanns, R.
- ; p. 273-306
- The UN Model and the BRICS countries - another view
- Gutiérrez, C.
- ; p. 307-339
- Extent
- XXIV, 341 p.
- Isbn
- 9789087221904
- Isbn Type
- (IBFD eBook)
- Label
- Taxation of business profits in the 21st century : selected issues under tax treaties
- Contents
-
- At the disposal of - the way towards a broader concept
- Popa, O.
- ; p. 3-26
- A certain degree of permanence - between temporary and everlasting business activities
- Perdelwitz, A.
- ; p. 27-55
- In the name of clarity : defining a dependent agent permanent establishment
- Obuoforibo, B.R.
- ; p. 57-78
- Withholding taxes on services income - a 21st century outlaw or a necessary evil?
- Law, S.B.
- ; p. 79-102
- Controversies involving the taxation of cross-border telecommunication income : is there a need for new rules?
- Cotrut, M.
- ; p. 103-132
- The authorized OECD approach : an overview
- Bernales, R.
- ; p. 135-181
- Capital structure and financing of permanent estabishments
- Nouel, L.
- ; p. 183-208
- Permanent establishments and intangibles : when did notional royalties become a reality?
- Vlasceanu, R.
- ; p. 209-229
- How fiction becomes reality : equal treatment for permanent establishments and resident enterprises
- Kulcsár, T.
- ; p. 231-250
- The applicability of the AOA to existing tax treaties - a matter of interpretation?
- van Boeijen-Ostaszewska, O.
- ; p. 251-272
- Implementation of the authorized OECD approach by OECD member countries
- Kosters, B.
- Offermanns, R.
- ; p. 273-306
- The UN Model and the BRICS countries - another view
- Gutiérrez, C.
- ; p. 307-339
- Extent
- XXIV, 341 p.
- Isbn
- 9789087221904
- Isbn Type
- (IBFD eBook)
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