Essays about: "Laura Mariel Alejandro"

Found 1 essay containing the words Laura Mariel Alejandro.

  1. 1. 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