International Taxation of Permanent Establishments

Principles and Policy

Nonfiction, Reference & Language, Law, Taxation, Business & Finance
Cover of the book International Taxation of Permanent Establishments by Michael Kobetsky, Cambridge University Press
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Author: Michael Kobetsky ISBN: 9781139139823
Publisher: Cambridge University Press Publication: September 15, 2011
Imprint: Cambridge University Press Language: English
Author: Michael Kobetsky
ISBN: 9781139139823
Publisher: Cambridge University Press
Publication: September 15, 2011
Imprint: Cambridge University Press
Language: English

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.

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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.

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