Number 10-2006 contains the following:
 

This article focuses on the core US source rules and particularly the first of the functions that has been assigned to such rules - their contribution to the assertion of US authority to impose tax on foreign persons. The purpose of the article is to explore the current state of inbound "source rule law" in the United States and to prepare the ground for an inquiry whether the fast-developing commerce and technology of the 21st century call for a rethinking.

This article contends that the EU Member States have a unique opportunity to opt for a competitive corporate tax system in the form of an optional "common consolidated corporate tax base". By relying on capital-import neutrality and an exemption method to address double taxation, the Member States could enhance their competitiveness and make the attainment of the Lisbon objectives more realistic.

The takeover of several high-profile Danish companies by private equity funds in recent years has sparked an intensive debate in Denmark on the effects of this trend. In December 2005, the Minister of Taxation presented a bill which proposed, inter alia, to expand significantly several of Denmark's anti-avoidance provisions, including the rules on thin capitalization, the withholding tax on interest and transfer pricing, in order to target the structures used.

This article examines the taxation of permanent establishments under Art. 7 of the OECD Model Tax Convention. The article first looks at how Art. 7 attributes business profits to permanent establishments. It also examines the separate entity method in Art. 7(2) and the interaction between Arts. 7(1) and (2) in allocating profits to a permanent establishment. The article then considers Art. 7(3) and the extent to which it prescribes the single entity approach for allocating expenses to a permanent establishment. The article concludes with an examination of the interaction between Arts. 7(2) and (3).