INTERNATIONAL TAXATION OF PERMANENT ESTABLISHMENTS by Michael Kobetsky ( 9780521516327 )

Item Details

Title:

INTERNATIONAL TAXATION OF PERMANENT ESTABLISHMENTS
PRINCIPLES AND POLICY

By:

Michael Kobetsky

Format:

Hardback

List price:

£138.00

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£120.75

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£17.25

ISBN 10:

0521516323

ISBN 13:

9780521516327

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Publisher:

CAMBRIDGE UNIVERSITY PRESS

Pub. date:

15 September, 2011

Series:

Cambridge Tax Law Series

Pages:

468

Description:

This book analyses the principles for attributing profits to branches of multinational enterprises for tax purposes under the OECD Model Tax Convention.

Synopsis:

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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Imprint:

Cambridge University Press

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