Title International taxation of permanent establishments : principles and policy / Michael Kobetsky

Published Cambridge : Cambridge University Press, 2011

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Description 1 online resource Series Cambridge tax law series Cambridge tax law series. Contents Cover; Title; Copyright; Contents; Abbreviations; 1 Introduction; 2 International taxation: 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 Tax Treaty and Commentary; 6 Defining the personality of permanent establishments under former Article 7 and the pre-2008 Commentary and the 2008 Commentary; 7 Intra-bank loans under the pre-2008 Commentary and 1984 Report; 8 Intra-bank interest under the 2008 Report Summary 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 Bibliography Includes bibliographical references and index Notes Print version record Subject International business enterprises -- Taxation -- Law and legislation. Branches (Business enterprises) -- Taxation -- Law and legislation Business enterprises, Foreign -- Taxation -- Law and legislation. Double taxation -- Treaties. LAW -- Military. Branches (Business enterprises) -- Taxation -- Law and legislation Business enterprises, Foreign -- Taxation -- Law and legislation Double taxation International business enterprises -- Taxation -- Law and legislation Genre/Form Treaties Form Electronic book ISBN 9780521516327 0521516323 9786613316523 6613316520 1139141503 9781139141505 9781139137485 1139137484 9781139144827 1139144820 1283316528 9781283316521 9780511977855 0511977859

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