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Vol 21 No 10 Oct/Nov 2016

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This book is now Out of Print.
A new edition has been published, the details can be seen here:
Permanent Establishments: A Domestic Taxation, Bilateral Treaty and OECD Perspective 5th ed isbn 9789041167279

Permanent Establishments: A Domestic Taxation, Bilateral Treaty and OECD Perspective 4th ed

Edited by: Ekkehart Reimer, Stefan Schmid, Marianne Orell

ISBN13: 9789041159496
New Edition ISBN: 9789041167279
Previous Edition ISBN: 9789041138989
Published: April 2015
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: Out of print



Low stock.

Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country.

The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Providing all the guidance you need, the new edition of Permanent Establishments: A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective covers the treatment of permanent establishments both in domestic tax practice and in the network of double taxation conventions from a truly international perspective.

The fourth edition has been updated by teams of experts from each of the 20 countries profiled to ensure that you benefit from coverage of the latest developments in this field.

How will Permanent Establishments: A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective benefit you?

  • Practical guidance on a variety of complex PE issues to allow you to act with confidence.
  • Understand the latest developments with expert analysis of the latest OECD developments in the context of Articles 5 and 7 of the OECD Model Tax Convention (2014 update).
  • Gain international understanding with 20 country chapters covering domestic PE issues as well as country-specific treaty developments.
The fourth edition of Permanent Establishments: A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective, by Ekkehart Reimer, Stefan Schmid and Marianne Orell, has been developed to provide a thorough examination of the latest developments in the law surrounding Permanent Establishments and is an invaluable guide for all those working in international taxation.

Subjects:
Taxation
Contents:
About the Editors
List of Abbreviations
Preface
General Perspective
Permanent Establishment in the OECD Model Tax Convention Ekkehart Reimer
Country Perspectives

Australia Peter Collins & Hamish McElwee
Austria Herbert Greinecker & Gülay Karatas
Belgium Pascal Janssens, Bertrand Vandepitte & Sofie Van de Perre
China Matthew Mui & Alan Yam
Denmark Søren Jesper Hansen, Elizabeth Brandt & Lene Munk Rasmussen
Estonia Iren Lipre & Karl-Rauno Miljand
France Renaud Jouffroy & Emmanuel Raingeard de la Blétière
Germany Claus Jochimsen & Maximilian Schrepfer
Hungary Ákos Burján & Ibolya Tóth
India Ketan Dalal, Vishal J. Shah & Smit Sheth
Italy Fabrizio Acerbis & Francesco Nuzzolo
Japan Yoshiyasu Okada & Yumiko Arai
The Netherlands Suzanne Boers, Hein Vermeulen & Ciska Wisman
Russia Mikhail Filinov, Valeria Lukina, Boris Ostrovskiy & Dmitriy Yasnovskiy
South Africa David Lermer, Johann Hattingh & Chris de Bruyn
Spain Ramón Mullerat & Anna Mallol
Sweden Gunnar Andersson & Carl Wattrang, PwC Sweden
Switzerland Stefan Schmid & Marianne Orell
United Kingdom Peter Cussons & Chloë Paterson
United States Oren Penn, Stephen Nauheim & Daniel Rinke

Index