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The Resource The attribution of profits to permanent establishments : the taxation of intra-company dealings

The attribution of profits to permanent establishments : the taxation of intra-company dealings

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The item The attribution of profits to permanent establishments : the taxation of intra-company dealings represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries. The book begins by examining how the dealings between a permanent establishment and the enterprise of which it is a part should be treated for tax treaty purposes. An overview of the historical development of Article 7 of the OECD Model Convention is provided, starting with the Draft Conventions prepared by the League of Nations up to the current OECD Model and Commentary, and taking into account the recent OECD Discussion Drafts. A comparative survey is presented in which the tax consequences of dealings between different parts of the same enterprise are analysed on the basis of the domestic law of the countries covered. Four different cases are scrutinized: the transfer of assets (both fixed assets and trading stock); the use of intangibles; the provision of services; and the transfer of funds. The survey covers 19 countries: Argentina, Austria, Belgium, Brazil, Canada, Chile, Finland, France, Germany, India, Italy, Mexico, the Netherlands, South Africa, Spain, Switzerland, the United Kingdom, the United States and Venezuela. A summary of the survey is included at the end of this part. The book concludes by discussing selected issues, such as the application of the PE non-discrimination clause, the effects of EC legislation and possible source taxation in relation to the tax treatment of intra-company dealings

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Label: The attribution of profits to permanent establishments : the taxation of intra-company dealings

Title: The attribution of profits to permanent establishments : the taxation of intra-company dealings

Summary: This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries. The book begins by examining how the dealings between a permanent establishment and the enterprise of which it is a part should be treated for tax treaty purposes. An overview of the historical development of Article 7 of the OECD Model Convention is provided, starting with the Draft Conventions prepared by the League of Nations up to the current OECD Model and Commentary, and taking into account the recent OECD Discussion Drafts. A comparative survey is presented in which the tax consequences of dealings between different parts of the same enterprise are analysed on the basis of the domestic law of the countries covered. Four different cases are scrutinized: the transfer of assets (both fixed assets and trading stock); the use of intangibles; the provision of services; and the transfer of funds. The survey covers 19 countries: Argentina, Austria, Belgium, Brazil, Canada, Chile, Finland, France, Germany, India, Italy, Mexico, the Netherlands, South Africa, Spain, Switzerland, the United Kingdom, the United States and Venezuela. A summary of the survey is included at the end of this part. The book concludes by discussing selected issues, such as the application of the PE non-discrimination clause, the effects of EC legislation and possible source taxation in relation to the tax treatment of intra-company dealings

http://library.link/vocab/relatedWorkOrContributorName: Russo, R. (Raffaele)

http://library.link/vocab/subjectName

Label: The attribution of profits to permanent establishments : the taxation of intra-company dealings

Label: The attribution of profits to permanent establishments : the taxation of intra-company dealings

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