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Vol 22 No 10 Oct/Nov 2017

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International Taxation of Permanent Establishments: Principles and Policy


ISBN13: 9780521516327
Published: September 2011
Publisher: Cambridge University Press
Country of Publication: UK
Format: Hardback
Price: £103.00



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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.

Subjects:
Taxation
Contents:
1. Introduction
2. International tax: policy and law
3. Some shortcomings of the tax treaty system
4. History of tax treaties and the permanent establishment concept
5. The role of the OECD model and commentary
6. Defining the personality of permanent establishments under Article 7 and the pre-2008 commentary and 2008 commentary
7. Intra-bank interest under the pre-2008 commentary and 1984 report
8. Intra-bank interest under the 2008 commentary and the 2008 report
9. Business restructuring involving permanent establishments and the OECD transfer pricing methods
10. New Article 7 of the OECD model and commentary
11. Unitary taxation
12. Conclusion.

Series: Cambridge Tax Law Series

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International Tax Policy: Between Competition and Cooperation ISBN 9781107112100
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A Global Analysis of Tax Treaty Disputes ISBN 9781316507254
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Value Added Tax: A Comparative Approach 2nd ed ISBN 9781107042988
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£93.00
The Rise of the Value-Added Tax ISBN 9781107044128
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£82.00
Value Added Tax: A Comparative Approach 2nd ed ISBN 9781107617629
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£45.99
European Union Corporate Tax Law ISBN 9781107018990
Published May 2013
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£103.00
Corporate Tax Law: Structure, Policy and Practice ISBN 9781107033535
Published March 2013
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£103.00
Tax Expenditure Management: A Critical Assessment ISBN 9781107007369
Published February 2013
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£88.00
The Taxation of Corporate Groups Under Consolidation: An International Comparison ISBN 9781107033498
Published December 2012
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Resolving Transfer Pricing Disputes: A Global Analysis ISBN 9781107026599
Published November 2012
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£211.00
Income Tax in Common Law Jurisdictions: Volume 1 - From the Origins to 1820 ISBN 9781107411586
Published November 2012
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£45.99
Anglo-American Corporate Taxation: Tracing the Common Roots of Divergent Approaches ISBN 9780521887762
Published September 2011
Cambridge University Press
£88.00
Tax Policy, Women and the Law: UK and Comparative Perspectives ISBN 9780521878036
Published November 2010
Cambridge University Press
£56.00
International Commercial Tax ISBN 9780521853118
Published July 2010
Cambridge University Press
£100.00
The Victorian Taxpayer and the Law: A Study in Constitutional Conflict ISBN 9780521899246
Published April 2009
Cambridge University Press
£93.00
International Tax as International Law: An Analysis of the International Tax Regime ISBN 9780521618014
Published October 2007
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£29.99
Income Tax in Common Law Jurisdictions: Volume 1 - From the Origins to 1820 ISBN 9780521870832
Published November 2006
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£103.00