Essays about: "Authorised OECD Approach"
Showing result 1 - 5 of 6 essays containing the words Authorised OECD Approach.
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1. The Authorised OECD Approach and the Attribution of Profit to Banks´PEs : How far is the functionally separate entity approach fully achievable?
University essay from Uppsala universitet/Juridiska institutionenAbstract : This thesis´ aim is to analyse the extension of the fuctionally separate entity approach (FSEA) used in order to attribute a proper amount of profit to banks´ permanet establishment (PE) and the related implication in the authorised OECD approach (AOA). From a general perspective in fact, under the FSEA a PE is treated as being a separate entity from the head office, functions, assets, risks and funding shall be attributed as it was a separate legal entity. READ MORE
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2. Permanent Establishment : With respect to attribution of income and the question of documentation of internal dealings
University essay from IHH, RättsvetenskapAbstract : In 2008 the Committee of Fiscal Affairs of OECD published its report on profit attributable to a permanent establishment. In 2010 article 7 of the OECD model tax convention was reformed, and the report was revised to better conform to the article. READ MORE
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3. Attributing Free Capital and Profit to Permanent Banking Establishments
University essay from IHH, RättsvetenskapAbstract : By September 2010, in its ongoing effort to clarify the subject of taxing a permanent establishment, the OECD launched a new article 7 in its model tax convention together with a revised version of the report on the attribution of profits to permanent establishments. The article and the report contain a new order of taxation, where a permanent establishment should, in almost all aspects, be treated as a separate entity. READ MORE
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4. Attribution of Profits to Dependent Agent Permanent Establishments : The dual taxpayer approach versus the single taxpayer approach
University essay from IHH, RättsvetenskapAbstract : Business profits constitute the main part of income derived through international business and these profits are only to be taxed in the home state of the enterprise. However, if the enterprise conducts business in a host state through a PE, the profits attributable to the PE are taxable in the host state. READ MORE
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5. The Authorised OECD Approach - The Implications of the OECD Report of July 2008
University essay from Lunds universitet/Juridiska institutionenAbstract : Fördelning av vinster till fasta driftställen har länge varit ett omdiskuterat ämne i den skatterättsliga debatten. De internationella skatterättsliga principerna för hur detta ska ske återfinns i Artikel 7 i OECD:s modell för skatteavtal beträffande inkomst och förmögenhet (modellavtalet). READ MORE
