Permanent Establishments
� Domestic Taxation, Bilateral Tax Treaty and OECD Perspective
Författare:Reimer Ekkehart , Schmid Stefan , Orell Marianne
Titel:Permanent Establishments � Domestic Taxation, Bilateral Tax Treaty and OECD Perspective
Upplaga:5 uppl.
Omfång:936 sid.
Ämnesord:Skatterätt , Internationell rätt

Pris: 3316 SEK exkl. moms


Permanent Establishments provides a comprehensive overview of conceptional and practical aspects of taxation of permanent establishments (PEs) in different jurisdictions. Although two decades ago, PEs (or at least certain types) were labelled as ‘the black hole’ of international taxation, they have emerged as an innovative and meaningful concept in IFA’s 2009 World Congress in Vancouver, and are now a key facet of international taxation. The PEs constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. This book discusses about the fact patterns of cases that lead to PEs and the allocation of profits to such a PE.

What’s in this book:

This academically rigorous yet thoroughly practical work provides:

- comprehensive guidance on a variety of complex PE issues;
- analysis of the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention (2014 update);
- the 2015 proposals of the G20/OECD BEPS project (action item 7); and
- the most recent EU Recommendation on the implementation of measures against tax treaty abuse of 28 January 2016.

Twenty-one country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. This year's edition also covers the latest OECD BEPS developments and its impact on the taxation of PEs. This book is the result of contributions received from an array of experts from around the globe – all of them work within, or have a significant background in this academia.

How this will help you:

This book serves a springboard for readers to better assess whether the set-up of their business operations may result in a taxable presence in a particular jurisdiction. The general part of this work explicates the meaning of all relevant terms of Articles 5 and 7 OECD MC in detail taking into consideration the relevant case law and literature published to the end of 2015. The country chapters assembled in this book reflect extensive experience with, and address deviations from, OECD standards, thereby helping practitioners and academicians to gain insight into the PE practice in the countries profiled.

Fabrizio Acerbis,
Gunnar Andersson,
Maret Ansperi,
Yumiko Arai,
Elizabeth Brandt,
Ákos Burján,
Peter Collins,
Mike Cooper,
David Cuellar,
Ketan Dalal,
Veronika Daurer,
Frank Feng,
Mikhail Filinov,
Sandra Fleurier,
Jose Antonio Gonzalez,
Herbert Greinecker,
Søren Jesper Hansen,
Mauricio Hurtado,
Martin Jann,
Renaud Jouffroy,
Natalia Kuznetsova,
David Lermer,
Iren Lipre,
Anna Mallol,
Hamish McElwee,
Osman Mollagee,
Matthew Mui,
Ramón Mullerat,
Luis Felipe Muñoz,
Stephen Nauheim,
Francesco Nuzzolo,
Yoshiyasu Okada,
Marianne Orell,
Oren Penn,
Martin Poulsen,
Emmanuel Raingeard de la Blétière,
Lene Munk Rasmussen,
Ekkehart Reimer,
Daniel Rinke,
Stefan Schmid,
Maximilian Schrepfer,
Vishal J. Shah,
Smit Sheth,
Maarten Temmerman,
Ibolya Tóth,
Sofie Van de Perre,
Hein Vermeulen,
Huili Wang,
Sonia Watson,
Carl Wattrang,
Ciska Wisman,
Raymond Wong
& Alan Yam.
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