International taxation of permanent establishments : principles and policy /

The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article...

Ausführliche Beschreibung

Gespeichert in:
1. Verfasser:
Kobetsky, Michael
Format:
Elektronisch E-Book
Sprache:
Englisch
Veröffentlicht:
Cambridge : Cambridge University Press, 2011.
Zusammenfassung:
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
Umfang:
1 online resource (vii, 459 pages) : digital, PDF file(s).
Anmerkungen:
Title from publisher's bibliographic system (viewed on 05 Oct 2015).
ISBN:
9780511977855 (ebook)
DOI:
10.1017/CBO9780511977855
Schlagworte:
International business enterprises > Taxation > Law and legislation.
Branches (Business enterprises) > Taxation > Law and legislation.
Business enterprises, Foreign > Taxation > Law and legislation.
Double taxation > Treaties.
Bezugswerke:
Links: