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Permanent Establishments

This online collection is the only per-country study of the role of permanent establishments in international tax law and their impact on international business.
 
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Title:

Permanent Establishments

Editor(s):
Giulia Gallo, Prof. Dr. Irene J.J. Burgers
Type of publication:

Online Collection

Access:

Up to five users. View purchase information

Price:
Available on request
Enquire / Order via Email
tab_1
Title:

Permanent Establishments

Editor(s):
Andrei Cracea, Prof. Dr. Irene J.J. Burgers
Type of publication:

Online Collection + Historical Tax Archives

Access:

Up to five users. View purchase information

Price:
Available on request
Enquire / Order via Email
Permanent Establishments

Why subscribe?

This online collection gives a clear, practical and in-depth overview of the taxation of permanent establishments in different jurisdictions. The issue of whether cross-border activities constitute a permanent establishment, and how much profit should then be allocated to it, is an increasingly important factor for tax practitioners dealing with tax accounting and tax compliance issues, and related tax risk management.

This publication provides guidance in determining the existence of a permanent establishment, attributing profits to a permanent establishment and fulfilling related administrative obligations. Special attention is paid to specific industries, such as banking and financial enterprises, insurance companies, global trading companies, and the oil and gas industry.
 
In addition, the collection includes six general chapters providing a detailed analysis of the relevant articles of the OECD and UN Models and related developments at the EU level, as well as addressing potential VAT implications and e-commerce issues connected to the permanent establishment topic. 
 
Information is presented in an easy-to-follow manner, making a clear distinction between the tax implications arising for domestic permanent establishments of non-resident taxpayers and foreign permanent establishments of resident taxpayers, in both treaty and non-treaty situations. Moreover, a number of practical case studies have also been incorporated to provide tax practitioners with answers to issues they face in their daily activities.

 

Downloads

 

Main contents

 

  • Tax News Service – Latest developments in international tax including BEPS and MLI
  • Topical Analyses (Permanent Establishments)
  • Models (OECD, UN, etc.)
  • Primary Sources – legislative documentation on direct taxes from the European Union and documentation from other international organizations

Tools and Action Functionality

 

  • Compare two similar country chapters easily, using standardized outlines. An ideal tool for comparative tax research.
  • Compare similar tables for multiple countries, such as BEPS Country Monitor
  • Fits the needs of tax specialists, professional advisers, policymakers and other practitioners involved in international tax practice and dealing with permanent establishment issues
  • Sections of country chapters affected by recent developments feature direct links to the relevant tax news
  • Up-to-date information on relevant BEPS and MLI developments
  • Targeted information on specific industries with respect to each jurisdiction covered
  • Standardized outlines enabling side-by-side comparison of legislation and practice of different jurisdictions
  • Links to selected relevant information (e.g. on corporate income tax, international tax matters, and allocation of assets and risks to permanent establishments) contained in the Country Surveys and Transfer Pricing collections
  • Practical case studies included in each country chapter
  • Access to models and other relevant documentation of international organization (e.g. OECD and UN) and the European Union
  • Easy to use and quick search facilities
  • Access for up to five users (additional users for a small fee)
  • Frequent updates
  • Create and save unique personalized searches and documents under your Favourites
Argentina, Australia, Brazil, Canada, China (People’s Rep.), Denmark, Estonia, France, Germany, Hong Kong, Hungary, India, Indonesia, Ireland, Italy, Japan, Kazakhstan, Korea (Rep.), Malaysia, Mexico, The Netherlands, New Zealand, Norway, Poland, Portugal, Russia, South Africa, Spain, Sweden, Switzerland, Turkey, Ukraine, United Kingdom, United States, Uruguay

 

Why Historical Tax Archives?

As a tax practitioner, you may need to deal with tax issues from the past, due to protracted litigation procedures. 
 
To help you find the right information quickly, IBFD has made available the Historical Tax Archives dating back to 2009. This additional product allows you to quickly view and compare historical tax data, so that you can analyse the main changes across different time periods.
 
For an extra fee, you can order our Historical Tax Archives together with Permanent Establishments, by clicking on the tab “Online Collection + Archives” above. 
 
If you already are a subscriber to Permanent Establishments, you can order the Historical Tax Archives at a small surcharge on the annual subscription price. For more information, please contact Customer Support.

 

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