International taxation of permanent establishments : principles and policy /

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Bibliographic Details
Author / Creator:	Kobetsky, Michael.
Imprint:	Cambridge : Cambridge University Press, 2011.
Description:	1 online resource
Language:	English
Series:	Cambridge tax law series Cambridge tax law series.
Subject:	International business enterprises -- Taxation -- Law and legislation. Branches (Business enterprises) -- Taxation -- Law and legislation. Business enterprises, Foreign -- Taxation -- Law and legislation. Double taxation -- Treaties. Branches (Business enterprises) -- Taxation -- Law and legislation. Business enterprises, Foreign -- Taxation -- Law and legislation. Double taxation. International business enterprises -- Taxation -- Law and legislation. Treaties.
Format:	E-Resource Book
URL for this record:	http://pi.lib.uchicago.edu/1001/cat/bib/11827499

Hidden Bibliographic Details
ISBN:	9780521516327 0521516323 9786613316523 6613316520 1139141503 9781139141505 9781139137485 1139137484 9781139144827 1139144820 1283316528 9781283316521 9780511977855 0511977859
Notes:	Includes bibliographical references and index. Print version record.
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.
Other form:	Print version: 9786613316523
Standard no.:	9786613316523

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