International taxation of permanent establishments : principles and policy /

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Bibliographic Details
Author / Creator:	Kobetsky, Michael, author.
Imprint:	Cambridge : Cambridge University Press, 2011.
Description:	1 online resource (vii, 459 pages) : digital, PDF file(s).
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.
Format:	E-Resource Book
URL for this record:	http://pi.lib.uchicago.edu/1001/cat/bib/12599388

Hidden Bibliographic Details
ISBN:	9780511977855 (ebook) 9780521516327 (hardback)
Notes:	Title from publisher's bibliographic system (viewed on 05 Oct 2015).
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: 9780521516327

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