How Fixed Is a Permanent Establishment?: 42 (Series on International Taxation, 42) - Image 1

£167.00

Kluwer Law International How Fixed Is a Permanent Establishment?: 42 (Series on International Taxation, 42)

Name: How Fixed Is a Permanent Establishment?: 42 (Series on International Taxation, 42)
Brand: Kluwer Law International
Price: 167.0 GBP
Availability: InStock

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Description

Permanent establishment is the key concept for allocating taxation rights in respect of business income, and the question Is there a permanent establishment? is a tax treaty issue that advisers, government officials, and courts perennially confront. Based on a fixed link to the ground , the idea has become progressively more difficult to apply until, at this stage, re-evaluation has become a political necessity. If a permanent establishment may exist in the context of e-commerce, the concept of a geographical presence must be redefined. However, the question remains: Is e-commerce a sufficient reason for challenging the well-established permanent establishment nexus? Drawing on case law, administrative practice, and business decisions in numerous jurisdictions, the author discusses the permanent establishment criteria under conditions of e-commerce and the service economy. He shows that the OECD Model Convention and its commentaries already offer the basis for the evolution of the analysis of the concept, and that the preservation of permanent establishment protects and maintains the level playing field between capital importing and capital exporting economies.

Product Specifications

Brand: Kluwer Law International
Format: Hardcover
ASIN: 9041146628
Category: Books > Subjects > Business, Finance & Law > Law > International
Domain: Amazon UK
Release Date: 01 March 2013
Listed Since: 25 January 2013

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Kluwer Law International How Fixed Is a Permanent Establishment?: 42 (Series on International Taxation, 42)

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