Essays about: "Model Tax Convention"
Showing result 21 - 25 of 32 essays containing the words Model Tax Convention.
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21. Transfer Pricing and Business Restructurings : Risk Allocation as set out in Issues Notes 1 of the OECD Discussion Draft
University essay from IHH, RättsvetenskapAbstract : The purpose of this thesis is to analyze the notion of risk as set out in Issues Notes 1, in the document “Transfer Pricing Aspects of Business Restructurings: Discussion Draft for Public Comment”. Furthermore, the approach of this draft is compared with the authorized OECD approach, established in the 2010 Report on the Attribution of Profits to Permanent Establishments. READ MORE
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22. The interpretation of the term employer in Article 15(2) (b) OECD Model and its implication on short-term secondments - from a Swedish perspective
University essay from Lunds universitet/Juridiska institutionenAbstract : The global mobility is constantly increasing and numerous of international groups have recognised the need for a dynamic workforce. In order to adapt to the international market and to widen the knowledge within a multinational group, employees are seconded between affiliated companies. READ MORE
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23. 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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24. 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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25. Attribution of Profits to Permanent Establishments : How Should Swedish Legislation Conform to the OECD December 2006 Report?
University essay from IHH, RättsvetenskapAbstract : The purpose of this thesis is to establish whether the domestic legislation of Sweden is in tune with the OECD December 2006 report on the attribution of profits to permanent es-tablishments (December 2006 report) and if not how Sweden ought to conform. How to attribute business profits to a permanent establishment (PE) is laid down in Article 7 of the OECD Model Tax Convention on Income and on Capital. READ MORE
