Introduction -- The development of trade in services -- The theoretical justification for the use of the source principle in the taxation of international services -- A history of the treatment of cross-border enterprise services in the model tax conventions -- Domestic law on the taxation of inbound services -- Survey of treaty practices -- The application of the fixed place of business threshold to non-resident service providers -- The services PE -- Further fundamental issues in the treatment of services in the models -- Conclusions
Summary
This book contains a worldwide survey of double tax treaties with respect to cross-border services and critically analyses current guidance in the Model Tax Conventions
