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Autor:
Reimer Ekkehart, Roth Marianna Katharina, Urban Nathalie

Law
Editura / Producator:
Kluwer Law
Pret (estimativ): 1325.00 lei

9789041131232
Nr pagini (estimativ): 0
Poza 1 Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective
Detalii Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective
Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective  will consist of two parts:

Part One – PE: The Legal and Compliance Setting.

This section will feature a comprehensive – and highly practical – analysis of the concept of permanent establishment (PE), particularly as it’s embodied in Article 5 of the Model Convention. In a departure from virtually all the current literature, the presentation will afford the reader a truly actionable tool they can use to optimise decision making as it relates to PE in a “real world” setting. The work would initially concentrate on the PE-related issues of most concern to corporate interests: the notion of PE and the allocation of profits. Highlights include:

General Remarks

  • Origin of the “Permanent Structure of the rule Establishment” concept
  • Interpretation
  • Significance
Regarding Article 5 (1) of the OECD-, United Nations-, and US-Models
  • The basic definition
  • Neighbouring locations
  • Type of business,
  • Permanency productivity
  • Summary of the foregoing
  • Place of business
  • Leasing
  • Power of disposition
  • Personnel
  • Instrument, not object
  • Beginning and end of of activity Permanent establishment
  • Link to a geographical point
Regarding Article 5 (2) of the OECD-, United Nations-, and US-Models
  • Main features
  • Office
  • Place of management
  • Factories and workshops
  • Branch
  • Extraction of natural resources
Regarding Article 5 (3) of the OECD-, United Nations-, and US Model
  • Main features – Aggregate building sites
  • Building site or construction – Interruptions of the or installation project minimum period
  • Computation of the – Supervising and control time requirement – Exploration activities - Start and end of the - Services constituting a minimum period Permanent Establishment
Regarding Article 5 (4) of the OECD-, United Nations-, and US-Models
  • Main features
  • The exceptions in detail
  • Facilities for storage, display and (OECD and US) delivery
  • Stocks for storage, display and (OECD and US) delivery
  • Stocks for processing by another enterprise
  • Solely purchasing or collecting information
  • Other preparatory or auxiliary activities
  • Several preparatory and/or auxiliary activities combined

Regarding Article 5 (5) of the OECD-, United Nations-, and US-Models

  • Main features
  • Sequence of tests
  • Authorised contracting agents
  • Order-filling agent delivering
  • Lasting activity goods from stock (UN Model
Regarding Article 5 (6) of the OECD- and US-Models; Article 5 (7) of UN Model
  • Main features
  • Exclusive representation
  • Independence
  • Profit splitting
  • Ordinary course of business
Regarding Article 5 (6) of the UN-Model Regarding Article 5 (7) of the OECD- and US-Models; Article 5(8) of UN Model
  • Electronic Commerce
Part Two – Country-specificPE profiles designed to facilitate the reader’s decision making by allowing them to easily compare-and-contrast critical PE-related data over an array of key national jurisdictions. (Please see accompanying questionnaire outlining the issues covered.)

Countries covered:

Germany; -Hungary; India; -Italy; Japan; -Netherlands; Russia; -Spain; -Sweden; -Switzerland; -United Kingdom; -United States

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