How Fixed Is a Permanent Establishment?
Published on 14. February 2013
344 pages
978-90-411-6518-3 (ISBN)
Description
Permanent establishment is the key concept for allocating taxation rights in respect of business income, and the question è^-Is there a permanent establishment?è^- is a tax treaty issue that advisers, government officials, and courts perennially confront. Based on a è^-fixed link to the groundè^-, the idea has become progressively more difficult to apply until, at this stage, re-evaluation has become a political necessity. If a permanent establishment may exist in the context of e-commerce, the concept of a geographical presence must be redefined. However, the question remains: is e-commerce a sufficient reason for challenging the well-established permanent establishment nexus?
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Jean Schaffner
How Fixed Is a Permanent Establishment?
Book
02/2013
1st Edition
Kluwer Law International
€248.51
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