Essays about: "Permanent Establishment"

Showing result 1 - 5 of 40 essays containing the words Permanent Establishment.

  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

  2. 2. Deformation monitoring using GNSS:A study on a local network with preset displacements

    University essay from Högskolan i Gävle/Samhällsbyggnad

    Author : Peshawa Mohammed; [2019]
    Keywords : Deformation detection; processing parameters; GNSS; online post-processing;

    Abstract : In the past two decades, the number of observations and the accuracy of satellite-basedgeodetic measurements like Global Navigation satellite systems (GNSS) greatly increased,providing measured values of displacements and velocities of permanent geodetic stations.Establishment of the geodetic control networks and collecting geodetic observations, indifferent epochs, are a commonly used method for detection of displacements andconsequently disaster management. READ MORE

  3. 3. Learning to Exist Without Physical Connection : An Analysis of OECD Permanent Establishment Updates and Changes to the U.S. Substantial Nexus Test

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Isak Hawkinson; [2019]
    Keywords : ;

    Abstract : .... READ MORE

  4. 4. The Authorized OECD Approach for the attribution of profits to Permanent Establishments in a Post-BEPS World : An analysis of the Authorized OECD Approach for the attribution of profits to Permanent Establishments which arise from commissionaire arrangements under BEPS Action 7

    University essay from Uppsala universitet/Juridiska institutionen

    Author : Sevil Aliyeva; [2018]
    Keywords : The Authorized OECD Approach; commissionaire arrangements; attribution of profits to permanent establishments; BEPS; Action 7;

    Abstract : The BEPS Project has led to unprecedented changes in international taxation rules. In this respect, the recent changes made to the definition of permanent establishment (PE) under BEPS Action 7 target aggressive tax structures used by multinationals enterprises (MNEs). READ MORE

  5. 5. European Commission's proposal to implement a new permanent establishment nexus based on significant digital presence - Is it compliant with the EU Law and international tax principles?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Lara Nogueira; [2018]
    Keywords : Taxation of the Digital Economy; New permanent establishment nexus based on significant digital presence; Proportionality of the proposal and its compatibility with the Ottawa Principles.; Law and Political Science;

    Abstract : The taxation of the digital economy has become a relevant subject, as business models and value creation chains of all sectors have been transformed bringing challenges to the international tax system and parameters for the allocation of taxing rights between source and residence jurisdictions. In view of these changes, the European Commission has published two proposals for directives on the taxation of digital activities, proposing solutions to be harmonized into the system of direct taxation of Member States. READ MORE