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1. 1. Does the Substance over Form approach implemented as a result of the BEPS package reconciles the Permanent Establishment definition with the existence of economic allegiances?

   University essay from Lunds universitet/Institutionen för handelsrätt

   Author : Moisés Zúñiga Vargas; [2019]
   Keywords : Taxes; Permanent Establishment; economic allegiances; MLI; OECD; BEPS; Model Tax Convention; International taxation; Law and Political Science;

   Abstract : The Permanent Establishment (PE) concept plays a key role in the distribution of taxing rights between States by determining when the profits derived by an entity are taxable in a State other than the State of its residency. This concept, originally, evidenced the existence of sufficient economic allegiances between a non-resident entity and a State to justify taxation therein. READ MORE