Essays about: "virtual permanent establishment"

Found 2 essays containing the words virtual permanent establishment.

  1. 1. 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 fakulteten

    Author : Johan Brodd; [2018]
    Keywords : skatterätt; tax law; permanent establishment; corporate income taxation; significant digtal presence; significant economic presence; virtual permanent establishment; PE; Virtual PE; Law and Political Science;

    Abstract : 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

  3. 2. Profit-allocation based on value creation in the digital economy

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Tim Theunis; [2018]
    Keywords : Digital economy; value creation; tax; taxation; profit-allocation; permanent establishment; digital permanent establishment; virtual permanent establishment; formulary apportionment; arm s length principle; BEPS Action 1; BEPS Action 7; digitalization; digitalisation; European Commission; Directive; attribution of profits; value drivers; user jurisdiction; data; profit split method; transfer pricing; Law and Political Science;

    Abstract : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. READ MORE