International Taxation of Permanent Establishments: Principles and Policy

Author:   Michael Kobetsky
Publisher:   Cambridge University Press
ISBN:  

9780511977855


Publication Date:   07 September 2011
Format:   Undefined
Availability:   In stock   Availability explained
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International Taxation of Permanent Establishments: Principles and Policy


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Overview

The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.

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Author:   Michael Kobetsky
Publisher:   Cambridge University Press
Imprint:   Cambridge University Press (Virtual Publishing)
ISBN:  

9780511977855


ISBN 10:   0511977859
Publication Date:   07 September 2011
Audience:   Professional and scholarly ,  Professional & Vocational
Format:   Undefined
Publisher's Status:   Active
Availability:   In stock   Availability explained
We have confirmation that this item is in stock with the supplier. It will be ordered in for you and dispatched immediately.

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Michael Kobetsky teaches and researches in the fields of taxation law and international tax law at the Melbourne Law School, University of Melbourne.

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