Taxation

The Taxation of Permanent Establishments: A Critical Analysis of the Authorised OECD Approach and Its Implementation in German Tax Law under Specific Consideration of the Challenges Imposed to the PE Concept by the Digitalisation of the Economy

By Sven Hentschel
Springer-Verlag June 2021

Specifications

ISBN-13
9783658339999
Publisher
Springer-Verlag
Publication
June 2021
Format
Paperback
Jurisdiction
Switzerland ? Countri(es) for reference only

Details

This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.

Table of Contents

Fundamentals of the Taxation of Permanent Establishments
The Attribution of Profits to Permanent Establishments
Digitalisation of the Economy and Its Implications for the PE Concept
Adapting the International Corporate Tax System to the Digitalisation of the Economy
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