Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 3709405432
Total Pages : 452 pages
Book Rating : 4.7/5 (94 download)
Book Synopsis Dependent Agents as Permanent Establishments by : Michael Lang
Download or read book Dependent Agents as Permanent Establishments written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2014-07-04 with total page 452 pages. Available in PDF, EPUB and Kindle. Book excerpt: Dependent Agents as Permanent Establishments The article on business profits may be the most relevant one in tax treaties. If patterned after the OECD Model Tax Convention, this article allocates the exclusive taxing right over the profits of an enterprise to the residence country, unless the enterprise carries on business in the source country through a permanent establishment. Considering the importance of allocating taxation rights, tax authorities and courts of many countries have increasingly focused on the concept of agency permanent establishment. This book includes 12 chapters which provide an in-depth analysis of the key aspects that need to be taken into account for interpreting the concept of agency permanent establishment. It incorporates the perspectives of leading scholars and practitioners dealing with international tax cases. This book is designed to provide essential insights to academics, practitioners, tax officials and judges who deal or are interested in the field of international taxation.