Store International Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective, 6th Edition
Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective, 6th Edition by EKKEHART

Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective, 6th Edition

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Overview

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.

Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals.

This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective.

Last Updated 06/05/2018
Product Line Kluwer Law International
ISBN 9789041190482
SKU 10059395-0002
Table of 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, Martin Jann & Veronika Daurer
Belgium
Maarten Temmerman,Tom Stuer & Dennis Matthijs
China
Matthew Mui, Alan Yam, Raymond Wong, Frank Feng & Jessica Ma
Denmark
Søren Jesper Hansen, Lene Munk Rasmussen, Martin Poulsen & Lars Ellegård Holst
Estonia
Iren Lipre & Maret Ansperi
France
Renaud Jouffroy & Sandra Fleurier

Germany
Huili Wang & Mathias Schreiber
Hungary
Ákos Burján & Eszter Turcsik
India
Vishal J. Shah, Smit Sheth & Kunal Mehta
Italy
Fabrizio Acerbis & Francesco Nuzzolo
Japan
Yoshiyasu Okada & Yumiko Arai
Mexico
Mauricio Hurtado, David Cuellar, Luis Felipe Muñoz & Jose Antonio Gonzalez
The Netherlands
Hein Vermeulen & Ciska Wisman
Russia
Mikhail Filinov
South Africa
Osman Mollagee & David Lermer
Spain
Ramón Mullerat & Anna Mallol
Sweden
Peter Lindblad & Anna Berglund
Switzerland
Stefan Schmid & Marianne Orell
United Kingdom
Mike Cooper & Sonia Watson
United States
Oren Penn, Stephen Nauheim & Daniel Rinke
Index

Volumes