Essays about: "digital PE"
Showing result 6 - 10 of 14 essays containing the words digital PE.
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6. Do we need a new definition of Permanent Establishment for digital operations in Double Tax Treaties?
University essay from Lunds universitet/Institutionen för handelsrättAbstract : This master thesis investigates the need for a new Permanent Establishment (PE) definition for digital purposes in Double Tax Treaties (DTTs). In the core of the necessity to pursue the analysis of this, are the digital economic developments, and the challenges that they pose for international tax law, policymakers, countries, and businesses. READ MORE
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7. 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 handelsrättAbstract : 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
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8. Rethinking traditional source concepts in a digital economy
University essay from Uppsala universitet/Juridiska institutionenAbstract : The purpose of this thesis is to provide meaningful understanding of the current state of business activities, which generates the need for implementing new taxing measures, analyse the challenges arising from this need, as well as their cause. Furthermore, the aforementioned challenges will be explained in the context of existing traditional taxing systems and proposed measures will be analysed. READ MORE
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9. 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 handelsrättAbstract : 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
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10. Income taxation at the right place at the right time - An analysis of the need for a virtual permanent establishment
University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakultetenAbstract : In the last couple of years, taxation of the digital economy has become a subject that is on everybody’s mind. This has given rise to attempts from OECD and EU, amongst others, to solve this dilemma. READ MORE
