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The Concept Of Permanent Establishment In The Insurance Business
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Book Synopsis The Concept of Permanent Establishment in the Insurance Business by : Daniele Frescurato
Download or read book The Concept of Permanent Establishment in the Insurance Business written by Daniele Frescurato and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 430 pages. Available in PDF, EPUB and Kindle. Book excerpt: siness models adopted by insurance companies; and comparative analysis of double tax treaty policies adopted in a number of countries with respect to the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes. In a concluding chapter, the author proposes changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries, aligning such a definition to the regulatory framework in which insurance companies conduct their business in countries other than that of incorporation. As a highly significant and timely contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove of especial value to practitioners in international tax and insurance law, as well as professionals in the financial services sector and tax academics.
Book Synopsis Switzerland in International Tax Law by : Xavier Oberson
Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Book Synopsis Taxation of Bilateral Investments by : Carlo Garbarino
Download or read book Taxation of Bilateral Investments written by Carlo Garbarino and published by Edward Elgar Publishing. This book was released on 2019 with total page 375 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD’s guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.
Book Synopsis How Fixed Is a Permanent Establishment? by : Jean Schaffner
Download or read book How Fixed Is a Permanent Establishment? written by Jean Schaffner and published by Kluwer Law International B.V.. This book was released on 2013-02-01 with total page 344 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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. He examines in depth such elements as the following: ;the prevalence of commercial coherence over geographic coherence; the role of value-added tax; services permanent establishment; relevant definitions of ‘activity’ and ‘personnel’; multiple permanent establishments; supervision activity and sub-contracting; the differences between civil law and common law concepts of representation; particular treatment of the insurance sector; the ‘force of attraction’ concept; and specific exceptions (e.g., transportation, artists and sportsmen, rental income, agricultural activities, pipelines). Taking into account important distinctions between two model conventions (OECD and UN), as well as pertinent EU directives and the impact of EU law, the author proposes minor amendments to the OECD Model that adapt it to economic reality and current trends in jurisprudence and that can be implemented immediately. An appendix includes Article 5 and its commentaries as they have evolved since 1963, with the successive addenda and deletions. The author’s 20-plus years of experience as a tax lawyer lend the presentation a thoroughly practical aspect. The work addresses in more detail than any other publication the topic of profit allocation to a permanent establishment in the e-commerce world, an issue which is evolving rapidly in the current economic environment. Tax advisors, lawyers, and interested academics and policymakers will benefit from the book’s clear analysis of the conditions under which a permanent establishment not only should be preserved, but also how it is likely to be adapted in the future.
Book Synopsis Preventing the Artificial Avoidance of Permanent Establishment Status by : OCDE,
Download or read book Preventing the Artificial Avoidance of Permanent Establishment Status written by OCDE, and published by OCDE. This book was released on 2015-10-22 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 7.
Book Synopsis OECD Tax Policy Studies Taxing Insurance Companies by : OECD
Download or read book OECD Tax Policy Studies Taxing Insurance Companies written by OECD and published by OECD Publishing. This book was released on 2001-03-21 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study examines the difficult task of applying income taxation to the life and property and casualty insurance industries.
Book Synopsis Attribution of Profits to Permanent Establishments in the OECD-View by : Thomas Eulenpesch
Download or read book Attribution of Profits to Permanent Establishments in the OECD-View written by Thomas Eulenpesch and published by . This book was released on 2013-09 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt: Seminar paper from the year 2012 in the subject Business economics - Accounting and Taxes, grade: -, Rhine-Waal University of Applied Sciences, language: English, abstract: In my scientific writing I will write about the attribution of profits to Permanent Establishments in accordance with the updated OECD Model Tax Convention and the OECD Report on the attribution of profits to Permanent Establishments in the Versions of 2008 and 2010. First I will start with the definition of the Permanent Establishment in the German law and according to the OECD Model Tax Convention. Afterwards I will continue with the allocation of Profits to the Permanent Establishment by the two step analysis and the different transfer price methods. Additionally I will write about the hypothetical independent enterprises and special regulations for Banks, the trading of financial instruments and Insurance companies.
Book Synopsis The Taxation of Permanent Establishments by : Radhakishan Rawal
Download or read book The Taxation of Permanent Establishments written by Radhakishan Rawal and published by Spiramus Press Ltd. This book was released on 2006 with total page 551 pages. Available in PDF, EPUB and Kindle. Book excerpt: The dramatic advances in communications and technology that have taken place in recent years, combined with the progressive development of the Indian economy, have enticed many multi-national companies to tap the rich resources which India has to offer in terms of front-line business support services and customer relations. This has thrust the Indian tax system into the limelight, with multi-nationals and their advisers now needing to become familiar with the relevant aspects of Indian tax law and practice, and in particular, how India approaches the concept of permanent establishment and the circumstances in which a liability to tax in India could arise. This book's principal theme is the taxation of permanent establishments, taking as its starting point the OECD (Organisation for Economic Co-operation and Development) model convention on the avoidance of double taxation, and examining how the Indian courts and India's law-makers have interpreted the rules governing attribution of profits. The book examines the current issues to which the establishment of business centers in India by multi-nationals have given rise, relating how the law is developing to take account of these latest international business trends.
Book Synopsis Permanent Establishment by : Arvid Aage Skaar
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 957 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version September 1992 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version September 1992 written by OECD and published by OECD Publishing. This book was released on 1992-10-19 with total page 243 pages. Available in PDF, EPUB and Kindle. Book excerpt: Condensed version of the loose-leaf publication "Model tax convention on income and capital", containing the full text of the September 1992 Model Tax Convention, but omitting the historical notes and annexes, which include a detailed list of tax conventions between OECD member countries and the text of the Recommendation of 23 July 1992 from the OECD Council.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2018-03-16 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.
Book Synopsis Model Double Taxation Convention on Income and Capital 1977 by : OECD
Download or read book Model Double Taxation Convention on Income and Capital 1977 written by OECD and published by OECD Publishing. This book was released on 1977-10-19 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 1977 report contains the recommendations of the Committee on Fiscal Affairs for the avoidance of double taxation on income and capital. These recommendations result from consultation with member countries, following the 1963 Draft Convention. Double taxation is the taxation of a single ...
Book Synopsis United Nations Model Double Taxation Convention Between Developed and Developing Countries 2021 by : UNITED NATIONS.
Download or read book United Nations Model Double Taxation Convention Between Developed and Developing Countries 2021 written by UNITED NATIONS. and published by . This book was released on 2022 with total page 933 pages. Available in PDF, EPUB and Kindle. Book excerpt: The United Nations Model Double Taxation Convention between Developed and Developing Countries: 2021 Update is a publication geared towards the international community especially developing countries and countries with economies in transition. Double tax treaties aim to prevent unrelieved double taxation, in order to foster cross-border economic activity and the transfer of technology. The UN Model Tax Convention consists of articles on the treaty's scope and on definitions to be used in the treaty. For different kinds of income and capital, it allocates taxing rights before establishing how double taxation will be eliminated where the taxing rights are shared. It also includes articles that prevent certain forms of tax discrimination; provide for the exchange of tax information and assistance in tax collection between the treaty partners; allow the treaty partners to consult together, through the Mutual Agreement Procedure, to resolve disputes or address doubts concerning the treaty; and address certain types of treaty abuse. The most important changes included in the 2021 version of the UN Model address concerns expressed by developing countries regarding tax treaty obstacles to the taxation of foreign enterprises on income from automated digital services and on gains on so-called “offshore indirect transfers”. The 2021 UN Model also features new guidance on the application and interpretation of the definition of a permanent establishment, the concept of a beneficial owner, and the application of the Model's provisions to collective investment vehicles, pensions funds, and real estate investment trusts. This fifth edition of the UN Model Tax Convention culminates four years of work by the UN Tax Committee and its Subcommittees, supported by the Secretariat in the UN Department of Economic and Social Affairs. Since its first publication in 1980, the Model has been updated previously in 2001, 2011, and 2017.
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 308 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.
Book Synopsis Federal Income Taxation of Property and Casualty Insurance Companies by : Ernst & Young LLP
Download or read book Federal Income Taxation of Property and Casualty Insurance Companies written by Ernst & Young LLP and published by John Wiley & Sons. This book was released on 1996-04-30 with total page 548 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the first book to address the special rules that apply to the taxation of all property and casualty insurance companies, including life insurance companies with property/casualty insurance operations. It covers the special rules that apply to the taxation of captive insurance companies in addition to the general rules that are usually applicable to a captive insurance company. At the same time, it examines the fact that many healthcare organizations are now considered to be insurance companies and will be taxed as such under all the various healthcare reform proposals. Includes a sample tax return for property and casualty insurance companies, Form 1120PC, and guidance on how to read and review a property and/or casualty company annual report.
Book Synopsis The Taxation of Business Profits Under Tax Treaties by : Brian J. Arnold
Download or read book The Taxation of Business Profits Under Tax Treaties written by Brian J. Arnold and published by . This book was released on 2003 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt:
