International Taxation of Permanent Establishments - Principles and Policy

Informationen zum Autor Michael Kobetsky teaches and researches in the fields of taxation law and international tax law at the Melbourne Law School, University of Melbourne. Klappentext Analyses the principles for attributing profits to branches of multinational enterprises for tax purposes under the OECD Model Tax Convention. Zusammenfassung The tax treaties of OECD countries and many non-OECD countries are based on the OECD model. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under the business profits article (Article 7) of the OECD Model Tax Convention. Inhaltsverzeichnis 1. Introduction; 2. International tax: policy and law; 3. Some shortcomings of the tax treaty system; 4. History of tax treaties and the permanent establishment concept; 5. The role of the OECD model and commentary; 6. Defining the personality of permanent establishments under Article 7 and the pre-2008 commentary and 2008 commentary; 7. Intra-bank interest under the pre-2008 commentary and 1984 report; 8. Intra-bank interest under the 2008 commentary and the 2008 report; 9. Business restructuring involving permanent establishments and the OECD transfer pricing methods; 10. New Article 7 of the OECD model and commentary; 11. Unitary taxation; 12. Conclusion.

Product details

• Authors: Michael Kobetsky, Kobetsky Michael
• Publisher: Cambridge University Press ELT
• Languages: English
• Product format: Hardback
• Released: 15.09.2011
• EAN: 9780521516327
• ISBN: 978-0-521-51632-7
• No. of pages: 468
• Series: Cambridge Tax Law; Cambridge Tax Law; Cambridge Tax Law Series
• Subjects: Social sciences, law, business > Law > Miscellaneous; LAW / Taxation, Taxation, financial law, Financial services law and regulation, Banking law, Financial services law & regulation