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The Resource The taxation of permanent establishments : an international perspective

The taxation of permanent establishments : an international perspective

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The item The taxation of permanent establishments : an international perspective 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's principal theme is the taxation of permanent establishments (PEs), taking as its starting point the OECD model convention on the avoidance of double taxation, and examining how the Indian courts and India's law-makers have interpreted the rules governing attribution of profits. Chapters include: taxation of business profits; para 1 of article 7; force of attraction rule; para 2 of article 7; profits from transactions with self; para 3 of article 7 OECD and UN Model; para 4 of article 7; para 5 of article 7; para 6 & 7 of article 7 OECD Model, other paras of US Model and other provisions of article 7; para 2 of article 3; approaches for ascertaining income under the Income Tax Act; profits attributable to business operations in India; methods of profits attribution; effectively connected - PE and dividend, interest, royalties, fees for technical services, other income; PE and immovable property; PE and capital gains; PE and non-discrimination; service PE; PE and return filing requirements; taxation of a liaison office as PE; scope of option under section 90(2); and summary of OECD discussion drafts

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Label: The taxation of permanent establishments : an international perspective

Title: The taxation of permanent establishments : an international perspective

Summary: This book's principal theme is the taxation of permanent establishments (PEs), taking as its starting point the OECD model convention on the avoidance of double taxation, and examining how the Indian courts and India's law-makers have interpreted the rules governing attribution of profits. Chapters include: taxation of business profits; para 1 of article 7; force of attraction rule; para 2 of article 7; profits from transactions with self; para 3 of article 7 OECD and UN Model; para 4 of article 7; para 5 of article 7; para 6 & 7 of article 7 OECD Model, other paras of US Model and other provisions of article 7; para 2 of article 3; approaches for ascertaining income under the Income Tax Act; profits attributable to business operations in India; methods of profits attribution; effectively connected - PE and dividend, interest, royalties, fees for technical services, other income; PE and immovable property; PE and capital gains; PE and non-discrimination; service PE; PE and return filing requirements; taxation of a liaison office as PE; scope of option under section 90(2); and summary of OECD discussion drafts

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Label: The taxation of permanent establishments : an international perspective

Label: The taxation of permanent establishments : an international perspective

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