Essays about: "Permanent Establishment"
Showing result 26 - 30 of 51 essays containing the words Permanent Establishment.
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26. 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 handelsrättAbstract : 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
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27. Cross-border Loss Utilization Concerning the Tax Treatment of a Taxpayer’s Own Losses Attributable to a Permanent Establishment in Relation to the Territoriality Principle –From an International and EU law Perspective
University essay from Lunds universitet/Institutionen för handelsrättAbstract : The European Commission has acknowledged the lack of cross-border utilization of losses. Companies operating internationally want to have a possibility to offset losses against taxable profits at the same time or as soon as possible after the losses incurred. READ MORE
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28. Short-term responses of the field layer vegetation in a south Swedish deciduous forest after establishment of wild boars (Sus scrofa)
University essay from SLU/Southern Swedish Forest Research CentreAbstract : Inside the south Swedish national park Dalby Söderskog, wild boars (Sus scrofa L.) have been visiting since 2010. The presence of wild boars has earlier been proven to impact both soil and vegetation characteristics, both positively and negatively. READ MORE
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29. Modeling the potential impact of climate change on the distribution of Western Corn Rootworm in Europe
University essay from Lunds universitet/Institutionen för naturgeografi och ekosystemvetenskapAbstract : The Western Corn Rootworm (WCR), Diabrotica virgifera virgifera, is an important insect pest of corn, which has been introduced into Europe from Northern America in 1980s. Since then, its distributional range is continuously expanding over the Central and South-Eastern Europe. READ MORE
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30. PE Threshold for Business Profits in E-Commerce Context-To what extent does the present Permanent Establishment threshold influence the taxation of Electronic Commerce cross-border transactions?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : Issues related to attribution of profits already exist in the traditional economic framework and are of a different nature, however these issues seem to become more bothersome in transactions conducted in e-commerce context, with an electronic economy. The matter is similar to the traditional economic problems in regard to transfer pricing adjustments; however these issues are much more complex due to the e-commerce nature, especially when considering the fact that multinational enterprises may gather data from different jurisdictions, and for different purposes, which makes the tracing of the source of the data highly complex. READ MORE
