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Permanent Establishment in the OECD Model Tax Convention

Permanent Establishment in the OECD Model Tax Convention

Name: Permanent Establishment in the OECD Model Tax Convention
Brand: CCH Singapore
SKU: 9789814359146
Price: 485.00 HKD
Availability: OutOfStock
Author: Ekkehart Reimer
ISBN: 9789814359146

By Ekkehart Reimer

CCH Singapore July 2011

Specifications

ISBN-13: 9789814359146
Publisher: CCH Singapore
Publication: July 2011
Format: Paperback
Jurisdiction: International ? Countri(es) for reference only

Details

This book covers the treatment of permanent establishments (PE) both in domestic tax practice and in the network of double taxation conventions from a truly international perspective. It provides practical understanding and analysis of the concept of PE and references case law where applicable.

Features:

Gives the reader a truly actionable tool they can use to optimise decision making as it relates to PE in a ‘real world’ setting
Examines the PE-related issues of most concern to corporate interests: the notion of PE and the allocation of profits
Enable readers to analyse the latest OECD developments in the context of Articles 5 and 7 of the OECD Model Tax Convention (2010 update)

Contents Includes:

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 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 theUN-Model Regarding Article 5 (7) of the OECD- and US-Models; Article 5(8) of UN Model
• Electronic Commerce