Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective

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Permanent Establishments (PEs) are a key facet of international taxation.
They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management.
This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD developments in the context of Articles 5 and 7 of the OECD Model Tax Convention (2010 update) while 19 country
chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective.

The work consists of two parts:

Permanent Establishment in the OECD Model Tax Convention
This section features a comprehensive – and highly practical – analysis of the concept of permanent establishment (PE), particularly as it’s embodied in Article 5 of the Model Convention. In a departure from virtually all the current literature, the presentation affords the reader a truly actionable tool to optimize decision making as it relates to PE in a “real world” setting. The work initially concentrates on the PE-related issues of most concern to corporate interests: the notion of PE and the allocation of profits.

Country Perspectives
This part consists of country-specific PE profiles designed to facilitate the reader’s decision making by allowing easy comparison of critical PE-related data over an array of key national jurisdictions.

Countries covered:
Australia, Austria, Belgium, China, Denmark, Estonia, France, Germany, Hungary, India, Italy, Japan, The Netherlands, Russia, Spain, Sweden, Switzerland, United Kingdom, United States

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Editors: Ekkehart Reimer, Nathalie Urban, Stefan Schmid

Contributors: Fabrizio Acerbis, Gunnar Andersson, Joseph Andrus, Yumiko Arai, Edward Attard, Suzanne Boers, Elizabeth Brandt, Nina Budazhapova, Ákos Burján, Peter Collins, Peter Cusson, Ketan Dalal, Roger Gavelin, Herbert Greinecker, Søren Jesper Hansen, Shigeru Hasegawa, Caterina Innamorato, Bart Jansen, Pascal Janssens, Renaud Jouffroy, Peep Kalamäe, Gülay Karatas, David Karlsson, Natalia Kuznetsova, Andrea Linczer, Valeria Lukina, Oliver Mattern, Matthew Mui, Ramón Mullerat, Marianne Orell, Cees Peters, Emmanuel Raingeard de la Blétière, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Garrick Robinson, Stefan Schmid, Vishal J. Shah, Nathalie Urban, Erki Uustalu, Sofie Van de Perre, Pieter Van Den Berghe, Bijal Vora, Anna-Maria Widrig-Giallouraki, Cassie Wong, Alan Yam and Marcin Zimny.

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Price: EUR 276.00 / USD 372.00 / GBP 220.00
ISBN: 9888002211

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