Dependent Agents As Permanent Establishments
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Dependent Agents As Permanent Establishments
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2014-07-04
Dependent Agents As Permanent Establishments written by Michael Lang and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-07-04 with Law categories.
Dependent Agents as Permanent Establishments The article on business profits may be the most relevant one in tax treaties. If patterned after the OECD Model Tax Convention, this article allocates the exclusive taxing right over the profits of an enterprise to the residence country, unless the enterprise carries on business in the source country through a permanent establishment. Considering the importance of allocating taxation rights, tax authorities and courts of many countries have increasingly focused on the concept of agency permanent establishment. This book includes 12 chapters which provide an in-depth analysis of the key aspects that need to be taken into account for interpreting the concept of agency permanent establishment. It incorporates the perspectives of leading scholars and practitioners dealing with international tax cases. 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.
Dependent Agents As Permanent Establishments
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Author : Michael Lang
language : en
Publisher:
Release Date : 2014
Dependent Agents As Permanent Establishments written by Michael Lang and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Branches (Business enterprises) categories.
The Concept Of Permanent Establishment In The Insurance Business
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Author : Daniele Frescurato
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-04-22
The Concept Of Permanent Establishment In The Insurance Business written by Daniele Frescurato and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-04-22 with Law categories.
siness models adopted by insurance companies; and comparative analysis of double tax treaty policies adopted in a number of countries with respect to the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes. In a concluding chapter, the author proposes changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries, aligning such a definition to the regulatory framework in which insurance companies conduct their business in countries other than that of incorporation. As a highly significant and timely contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove of especial value to practitioners in international tax and insurance law, as well as professionals in the financial services sector and tax academics.
Switzerland In International Tax Law
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Author : Xavier Oberson
language : en
Publisher: IBFD
Release Date : 2011
Switzerland In International Tax Law written by Xavier Oberson and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Double taxation categories.
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Attribution Of Profits To Permanent Establishments
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2020-04-08
Attribution Of Profits To Permanent Establishments written by Michael Lang and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-04-08 with Law categories.
Attribution of Profits to Permanent Establishments: Issues and Developments The profit attribution to permanent establishments is one of the most controversial topics in international tax law. In recent years it was subject to various changes based on the introduction of the “Authorized OECD Approach” in 2008 and 2010, the outcomes of Final Report on OECD BEPS Action 7 and the Final Report on “Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7” from 2018 (with the previous Discussion-Drafts). This publication discusses the most important issues and recent developments related to the attribution of profits to permanent establishments. Starting with an in-depth analysis on the commonalities and differences between the profit attribution provisions in modern double tax treaties (ie Art 7 AOA vs Art 9 OECD/UN Models), it further deals with topics such as profit attribution to PEs and PE exemptions (Art 5 para 4), profit attribution to agency PEs (Art 5 para 5 and 6), and profit attribution to a "significant economic presence" and to market states. 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 authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the opinions on the issues at stake of representatives of tax administrations, multinationals and tax advisories, which completes this essential practical guideline.
Permanent Establishments
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Author : Ekkehart Reimer
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-06-07
Permanent Establishments written by Ekkehart Reimer and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-06-07 with Law categories.
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. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.
Preventing The Artificial Avoidance Of Permanent Establishment Status
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Author : OCDE,
language : en
Publisher: OCDE
Release Date : 2015-10-22
Preventing The Artificial Avoidance Of Permanent Establishment Status written by OCDE, and has been published by OCDE this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-22 with Double taxation categories.
This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.
Permanent Establishments A Planning Primer
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Author : John Huston
language : en
Publisher: Springer
Release Date : 1993-08-19
Permanent Establishments A Planning Primer written by John Huston and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1993-08-19 with Business & Economics categories.
This book is a comprehensive review of the tax treaty concept of a `permanent establishment' from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries. The book exhanstively deals with all aspects of the `fixed place of business' and `dependent agency' permanent establishments and the exceptions for independent agents, permitted ancilliary activities and parent subsidiary relationships. The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature.
Fundamentals Of Permanent Establishments
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Author : Robert L. Williams
language : en
Publisher: Kluwer Law International
Release Date : 2014
Fundamentals Of Permanent Establishments written by Robert L. Williams and has been published by Kluwer Law International this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Law categories.
This book provides an insight into business structuring and the related tax considerations. It covers all important aspects of fixed place of business and dependent agency types of PE, as well as the exceptions for independent agents, permitted ancillary activities, and parent-subsidiary relationships. It provides commentary on applicable rules and discusses regulations and case law from multiple jurisdictions. This new edition has entirely new chapters on e-commerce, supply chain and contract manufacturing structures and service PEs; updates of model treaty changes and PE rulings globally; and features implications of new developments in mineral extraction, real estate leasing and construction management. The book identifies key PE rulings not only in OECD countries, but also in the emerging BRIC countries.
The Taxation Of Permanent Establishments
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Author : Radhakishan Rawal
language : en
Publisher: Spiramus Press Ltd
Release Date : 2006
The Taxation Of Permanent Establishments written by Radhakishan Rawal and has been published by Spiramus Press Ltd this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with Business & Economics categories.
The dramatic advances in communications and technology that have taken place in recent years, combined with the progressive development of the Indian economy, have enticed many multi-national companies to tap the rich resources which India has to offer in terms of front-line business support services and customer relations. This has thrust the Indian tax system into the limelight, with multi-nationals and their advisers now needing to become familiar with the relevant aspects of Indian tax law and practice, and in particular, how India approaches the concept of permanent establishment and the circumstances in which a liability to tax in India could arise. This book's principal theme is the taxation of permanent establishments, taking as its starting point the OECD (Organisation for Economic Co-operation and Development) model convention on the avoidance of double taxation, and examining how the Indian courts and India's law-makers have interpreted the rules governing attribution of profits. The book examines the current issues to which the establishment of business centers in India by multi-nationals have given rise, relating how the law is developing to take account of these latest international business trends.