The Resource Transfer pricing, users participation and profit attribution to digital permanent establishments : a case study

Transfer pricing, users participation and profit attribution to digital permanent establishments : a case study

Label
Transfer pricing, users participation and profit attribution to digital permanent establishments : a case study
Title
Transfer pricing, users participation and profit attribution to digital permanent establishments : a case study
Creator
Subject
Language
eng
Summary
The recent introduction into the tax legislations of some countries of the definitions of "digital" permanent establishments (PEs) will necessarily generate the issue of assessing how much profit to attribute to a digital PE. This significant issue is still open to discussion and interpretation. This article aims at illustrating the issue by means of a practical example, as well as by providing some preliminary solutions to the issue
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 26 (2019), no. 2 ; p. 87-90
http://library.link/vocab/creatorName
Petruzzi, R
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • allocation of profits
  • digital PE
  • significant people functions
  • significant economic presence
Label
Transfer pricing, users participation and profit attribution to digital permanent establishments : a case study
Instantiates
Publication
Label
Transfer pricing, users participation and profit attribution to digital permanent establishments : a case study
Publication

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