Essays about: "BEPS action 7"
Found 1 essay containing the words BEPS action 7.
1. How can the proposed changes to the OECD tax model convention in action 1 and action 7 counter the issue of an artificial avoidance of a PE status?University essay from Lunds universitet/Institutionen för handelsrätt
Abstract : The purpose of this thesis is to clarify how, according to BEPS action 1 and action 7, can the amendments of the “specific activity exemptions” in article 5 paragraph 4 of the OECD Model Tax Convention on Income and Capital (the model convention) counter the issue of an artificial avoidance of a PE status. The main issues that are connected to the concept of a permanent establishment are artificial avoidance of the status of a permanent establishment, the use of transfer pricing rules in order to artificially allocate the profits of a permanent establishment to low tax states and finally that some enterprises that operate within the digital economy can avoid the status of a permanent establishment due to the lack of physical presence. READ MORE