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Taxation of Business Profits in the 21st Century - Selected Issues under Tax Treaties

This book highlights the controversies concerning the application of the PE concept and the Authorized OECD Approach on the attribution of profits under tax treaties.
 
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Title:

Taxation of Business Profits in the 21st Century

Subtitle:

Selected Issues under Tax Treaties

Series:

Volume 1 in the IBFD Tax Research Series

Editor(s):
Carlos Gutiérrez, Andreas Perdelwitz
Date of publication:
ISBN:

978-90-8722-189-8

Type of publication:

Print Book

Number of pages:

366

Terms:

Shipping fees apply. View shipping information

Other:

Preface by Hans Pijl

Price:
EUR 95 / USD 120 (VAT excl.)
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Title:

Taxation of Business Profits in the 21st Century

Subtitle:

Selected Issues under Tax Treaties

Series:

Volume 1 in the IBFD Tax Research Series

Editor(s):
Carlos Gutiérrez, Andreas Perdelwitz
Date of publication:
ISBN:

978-90-8722-190-4

Type of publication:

eBook in ePub format

Number of pages:

366

Other:

Please note: Adobe Digital Editions is required

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Price:
EUR 76 / USD 96 (VAT excl.)
Order eBook: ePub
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Title:

Taxation of Business Profits in the 21st Century

Subtitle:

Selected Issues under Tax Treaties

Series:

Volume 1 in the IBFD Tax Research Series

Editor(s):
Carlos Gutiérrez, Andreas Perdelwitz
Date of publication:
ISBN:

978-90-8722-189-8

Type of publication:

Online Book

Number of pages:

366

Access:

Up to 5 users. View purchase information

Other:

Preface by Hans Pijl

Price:
EUR 95 / USD 120 (VAT excl.)
Order Online Book
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Taxation of Business Profits in the 21st Century - Selected Issues under Tax Treaties

Why this book?

The taxation of business profits derived from cross-border activities is one of the core issues in international tax law. The key principle for the allocation of taxing rights between countries is laid down in article 7 of the OECD Model, which states that profits of a resident enterprise of a state shall be taxable only in that state unless the enterprise carries on business in another state through a permanent establishment situated therein. In the latter case, the profits that are attributable to the permanent establishment may be taxed in that other state.

The determination of the source state’s taxing rights basically requires two steps. First, it must be determined whether or not there is a permanent establishment in that state, as defined by article 5 of the OECD Model, and second, the profits attributable to that permanent establishment must be ascertained.

This book sheds light on a selection of issues surrounding the essential questions described above from a practical as well as from an academic perspective. The first part is dedicated to issues relating to the application of article 5 of the OECD Model and the problem of determining the existence of a permanent establishment in a state. The second part of the book relates to issues arising from article 7 of the OECD Model and the attribution of profits to a permanent establishment.
 

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Preface by Hans Pijl

 

Editor(s)

Carlos Gutiérrez and Andreas Perdelwitz
 

Author(s)

Roberto Bernales, Ola van Boeijen-Ostaszewska, Wooje Choi, Madalina Cotrut, Carlos Gutiérrez, Bart Kosters, Tamás Kulcsár, Shee Boon Law, Shiqi Ma, Luis Nouel, Belema R. Obuoforibo, René Offermanns, Pedro Paraguay, Andreas Perdelwitz, Oana Popa, Hiral Sejpal, Shreyas Shah and Ruxandra Vlasceanu

 

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