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Permanent Establishments

This online publication is the only per-country study covering all aspects of the taxation of permanent establishments, assisting subscribers in quickly identifying potential risks, managing their tax exposure and assessing the overall impact on their international businesses.
 
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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?

 

Due to the sophistication of the manner in which multinational enterprises currently carry on their businesses and structure their supply chains, the existence of a permanent establishment is a high priority item on the agenda of both tax practitioners and tax authorities, giving rise to a number of complex tax issues. Well aware of the great importance of the topic, the OECD has undertaken a number of projects in this regard, including the recent Base Erosion and Profit Shifting (BEPS) Project, which has had and continues to have a significant impact on the subject.

This online publication gives a clear and practical overview of the taxation of permanent establishments in different jurisdictions, providing a detailed description of the definition of permanent establishment under both domestic law and applicable tax treaties, including relevant case law, and an in-depth analysis of the taxation of profits attributable to domestic and foreign permanent establishments. Subscribers will also find additional information on reporting obligations and other administrative requirements, general and targeted anti-avoidance measures and the tax consequences of supply chain restructuring. 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, to keep track of the latest international developments in the permanent establishment area, 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 issues connected to the tax challenges arising from the digitalization of the economy.

Information is presented in an easy-to-follow manner, with a clear distinction made between the tax implications arising for domestic and foreign permanent establishments, 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 the 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 and MLI 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 organizations (e.g. the 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, the United Kingdom, the United States and 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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