The Taxation of Permanent Establishments: A Critical Analysis of the Authorised OECD Approach and Its Implementation in German Tax Law...

The Taxation of Permanent Establishments: A Critical Analysis of the Authorised OECD Approach and Its Implementation in German Tax Law...
ISBN-10
3658340002
ISBN-13
9783658340001
Category
Law
Pages
521
Language
English
Published
2021-06-26
Publisher
Springer Nature
Author
Sven Hentschel

Description

This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.

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