Taxation of Cross-Border Services
Series on International Taxation Volume 47
Building on a detailed analysis of the OECD and the UN tax treaty models as regards taxation of cross-border services – their shortcomings as well as their efficacy – this immensely informative and practical book responds knowledgeably and precisely to such questions as the following:
- What are the provisions for Service PEs in the UN and OECD models and commentary?
- What is the distinction between ‘fees’ and ‘fees for technical services’?
- How do the Articles dealing with ‘fees for technical service’, ‘permanent establishment’, and ‘independent personal services’ interact with each other?
|Resources||Table of Contents|
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About the Author.
Chapter 1 General Overview of Taxation of Cross-Border Services.
Chapter 2 FTS Article – Part I.
Chapter 3 FTS Article – Part II.
Chapter 4 Make Available.
Chapter 5 Effectively Connected Fees for Technical Services.
Chapter 6 Article 12 versus Article 14.
Chapter 7 Applicability of Other Source Article to the Fees for Technical Services.
Chapter 8 Service PE – Part I.
Chapter 9 Service PE – Part II.
Chapter 10 OECD Service PE Provision.
Chapter 11 Paragraph 2 of Article 3.
Chapter 12 United Nation’s Work on Taxation Services.
Chapter 13 Taxation under the Indian Domestic Law.