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Permanent Establishments


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Verlag :: Publisher

IBFD - International Bureau of Fiscal Documentation Publications

Permanent Establishments

Preis :: Price

Preise auf Anfrage / Prices on request

Das Angebot richtet sich nicht an Verbraucher i. S. d. § 13 BGB und Letztverbraucher i. S. d. PAngV.

Bestellnummer bei digento :: digento order number


Verlagsinformation :: Publisher's information

This highly topical online service comprises the most in-depth and comprehensive treatment of the practical and theoretical aspects of permanent establishments currently available. It is also the only per-country study of the role of permanent establishments in international tax law and their impact on international business.

Main contents

The service is divided into two sections:

  • The first section contains detailed commentaries on Articles of the OECD Model Tax Convention. The commentary on Article 5 (Permanent Establishments) is written by Dr Arvid A. Skaar; that on Article 7 (Business Profits) by Dr Irene J.J. Burgers. Also in this first section is a detailed study by Dr Otmar Thömmes and Klaus Eicker of the EC law aspects of permanent establishments.
  • The second section is devoted to comprehensive country chapters organized as follows:
    • Introduction, describing and contrasting resident and non-resident tax liability
    • Definition of a permanent establishment, including its interpretation in national law and tax treaties
    • Organization of a permanent establishment,including details of the practical aspects of setting up a permanent establishment
    • Determination of the taxable income of a permanent establishment, including methods for the avoidance of ouble taxation and the possibility for a set-off of losses; divided into "domestic" and "foreign" permanent establishments
    • Other issues

The benefits of this online publication are:

  • Easy to use and quick search facilities;
  • Frequent updating;
  • No more filing and storing;
  • Direct access anywhere, anytime; and
  • Simultaneous access for multiple users.

Countries covered: Belgium, Canada, France, Germany, Hungary, Ireland, Mexico, the Netherlands, Poland, Portugal, Spain, Switzerland, the United Kingdom, the United States, Argentina, Brazil and and Estonia. To be included: India and Tunisia.

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