Profit Attribution to Permanent Establishments : a Tax Treaty Perspective on the "single Taxpayer" Approach
| Author | : S.B. Law |
| Publisher | : |
| Total Pages | : |
| Release | : 2018 |
| ISBN-10 | : OCLC:1262826471 |
| ISBN-13 | : |
| Rating | : 4/5 ( Downloads) |
Book Synopsis Profit Attribution to Permanent Establishments : a Tax Treaty Perspective on the "single Taxpayer" Approach by : S.B. Law
Download or read book Profit Attribution to Permanent Establishments : a Tax Treaty Perspective on the "single Taxpayer" Approach written by S.B. Law and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In this article, the author provides a tax treaty perspective on the OECD's Additional Guidance on the Attribution of Profits to Permanent Establishments, Action 7 - 2017 Public Discussion Draft, observing that countries which continue to follow article 7 of the pre-2010 OECD Model and the current UN Model would likely not accept the "single taxpayer" approach of attributing zero or minimal profits to a permanent establishment.
