Essays about: "Formulary Profit Split"

Found 2 essays containing the words Formulary Profit Split.

  1. 1. Profit-allocation based on value creation in the digital economy

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Tim Theunis; [2018]
    Keywords : Digital economy; value creation; tax; taxation; profit-allocation; permanent establishment; digital permanent establishment; virtual permanent establishment; formulary apportionment; arm s length principle; BEPS Action 1; BEPS Action 7; digitalization; digitalisation; European Commission; Directive; attribution of profits; value drivers; user jurisdiction; data; profit split method; transfer pricing; Law and Political Science;

    Abstract : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. READ MORE

  3. 2. A Comparative Approach to the Order of Priority of the Allocation of Taxing Rights over Business Profits in the OECD MC, the UN MC and the Andean Pact MC – The PE broadening. An Argentinean example.

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Laura Mariel Alejandro; [2015]
    Keywords : OECD Model Convention; UN Model Convention; Andean Community; Andean Pact Model; Business Profits; Service PE; Service Permanent Establishment; Delivery PE; Delivery Permanent Establishment; Permanent Establishment; Argentina; Allocation of Business Profits; PE threshold; BEPS; Profit Split Method; Formulary Profit Split; Business and Economics;

    Abstract : The current OECD´s PE threshold requires either a direct physical presence (fixed place of business) or an indirect presence through a legal representative (dependent agent). On the other hand, Model Conventions such as the UN MC, provide a wider PE threshold, including income generating activities which are not included under the OECD PE threshold. READ MORE