Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective
A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship.
This book is designed to provide essential insights to academics, practitioners, tax officials and judges who deal or are interested in the field of international taxation.
Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business ...
This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium that took place in October 2019 at the WU Vienna University of Economics and Business.
The work addresses in more detail than any other publication the topic of profit allocation to a permanent establishment in the e-commerce world, an issue which is evolving rapidly in the current economic environment.
This book provides an insight into business structuring and the related tax considerations.
This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016.
The concept of permanent establishment is a cornerstone of international tax law. The authors analyze this concept in detail.
Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals.
discusses U.S. income tax treaty provisions that relate to business income associated with permanent establishments, the specialized treatment of real estate, and international shipping and aircraft activities.