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Showing result 1 - 5 of 6 essays matching the above criteria.
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1. 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 institutionenAbstract : 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
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2. 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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3. 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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4. 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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5. 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
