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Attribution of Profits to Agency Permanent Establishments : a Reconsideration of the Arm's Lenght [i.e. Length] Criterion?
Language: en
Pages:
Authors: D.J. Jiménez-Valladolid de L'Hotellerie-Fallois
Categories:
Type: BOOK - Published: 2016 - Publisher:

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According to the OECD report on the attribution of profits to permanent establishments (PEs), the attribution must be based on the so-called "authorized approac
Attribution of Profits to Permanent Establishments - Part 2
Language: en
Pages:
Authors:
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Type: BOOK - Published: 2011 - Publisher:

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QUESTIONS: I. Issue Six: In the case of a turnkey contract for supply and installation, commissioning and testing of large equipment, e.g. power projects, invol
The attribution of profits to permanent establishments
Language: en
Pages:
Authors:
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Type: BOOK - Published: 2006 - Publisher:

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The Arm's-length Standard is Alive and Well in Utah
Language: en
Pages:
Authors: R. Willens
Categories:
Type: BOOK - Published: 2018 - Publisher:

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This article discusses a recent victory for a Berkshire Hathaway company against a state tax agency. The Supreme Court of Utah found that a state statute based
Transfer Pricing and Dispute Resolution
Language: en
Pages: 807
Authors: Anuschka Bakker
Categories: Dispute resolution (Law).
Type: BOOK - Published: 2011 - Publisher: IBFD

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This book addresses the complexity, valuation and administrative nuances, and cultural impacts of resolving this significant cross-border issue when tax dispute