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"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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1
International Taxation of Permanent Establishments: Principles and Policy
2011, Cambridge University Press
in English
0511977859 9780511977855
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2
International Taxation of Permanent Establishments: Principles and Policy
2011, Cambridge University Press
in English
1139137484 9781139137485
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3
International taxation of permanent establishments: principles and policy
2011, Cambridge University Press
in English
0521516323 9780521516327
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International Taxation of Permanent Establishments: Principles and Policy
2011, Cambridge University Press
in English
1139141503 9781139141505
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International Taxation of Permanent Establishments: Principles and Policy
2011, Cambridge University Press
in English
1139142399 9781139142397
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