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International taxation of permanent establishments : principles and policy /
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...
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| Format: | Online Book |
| Language: | English |
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Cambridge :
Cambridge University Press,
2011.
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| Series: | Cambridge tax law series.
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| Subjects: | |
| Access: | Online version |
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| Summary: | 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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| Physical Description: | 1 online resource |
| Bibliography: | Includes bibliographical references and index. |
| ISBN: | 9780521516327 0521516323 9786613316523 6613316520 1139141503 9781139141505 9781139137485 1139137484 9781139144827 1139144820 1283316528 9781283316521 9780511977855 0511977859 |
| Access: | Electronic access restricted to Villanova University patrons. |