Essays about: "oecd permanent establishment"

Showing result 1 - 5 of 19 essays containing the words oecd permanent establishment.

  1. 1. Where is a digital company taxed?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Enora Boudinet; [2023]
    Keywords : Tax law; Digital company; a place of taxation; Permanent establishment; Traditional principle; Law and Political Science;

    Abstract : The identification of a permanent establishment is the principle used by the Member States of the European Union to determine whether a company is subject to the tax jurisdiction of a State. In the digital context, the notion of permanent establishment is often questioned by States, as companies can provide services remotely without having any physical presence in the territory of a State. READ MORE

  2. 2. Taxing the Digital Economy - A Legal Assessment of the Introduction of PIllar One to the Internal Market

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Gabija Ramanauskaite; [2021]
    Keywords : EU Law; International tax law; OECD; Pillar One; Nexus; Law and Political Science;

    Abstract : In the last decade, the progress of the digital economy has caused a rift in the international tax regime, which now faces several challenges. The current principles governing taxation rules are based on notions that business can only be conducted through physical presence. READ MORE

  3. 3. 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

  4. 4. 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

  5. 5. 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