Essays about: "FSEA"

Found 1 essay containing the word FSEA.

1. 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 institutionen

   Author : Davide Baldi; [2017]
   Keywords : AOA; PE; bank; banks; separate entity; FSEA; attribution of profit; authorised OECD approch; OECD; Basel; tax distortion;

   Abstract : 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