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International Taxation of Permanent Establishments

International Taxation of Trust Income. Series: Cambridge Tax Law.


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Popular Features. New Releases. Description The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments.

International Taxation of Permanent Establishments (Cambridge Tax Law Series)

The business profits article Article 7 of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. 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 profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

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Other books in this series. Add to basket. International Tax Policy Tsilly Dagan. Corporate Tax Law Peter Harris. International Commercial Tax Peter Harris.


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  • Value Added Tax Alan Schenk. Figuring Out the Tax Lawrence Zelenak. Tax Expenditure Management Mark Burton. Table of contents 1. Introduction; 2.

    Special order items

    International tax: policy and law; 3. Some shortcomings of the tax treaty system; 4.

    vevesentaree.cf History of tax treaties and the permanent establishment concept; 5. The role of the OECD model and commentary; 6.

    Permanent Establishment Business Connection -Deemed income- Meaning Sec 9(1) - International Tax

    Defining the personality of permanent establishments under Article 7 and the pre commentary and commentary; 7. Intra-bank interest under the pre commentary and report; 8.