Permanent Establishment in Cross Border Transactions

Year: 2010

Author: Ekkehart Reimer, Marianna Katharina Roth , Nathalie Urban

Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective will consist of two parts:

Part One PE: The Legal and Compliance Setting.

This section will feature a comprehensive and highly practical analysis of the concept of permanent establishment (PE), particularly as it s embodied in Article 5 of the Model Convention. In a departure from virtually all the current literature, the presentation will afford the reader a truly actionable tool they can use to optimise decision making as it relates to PE in a real world setting. The work would initially concentrate on the PE-related issues of most concern to corporate interests: the notion of PE and the allocation of profits.

Part Two Country-specificPE profiles designed to facilitate the reader s decision making by allowing them to easily compare-and-contrast critical PE-related data over an array of key national jurisdictions. (Please see accompanying questionnaire outlining the issues covered.)

Countries covered:

Germany; -Hungary; India; -Italy; Japan; -Netherlands; Russia; -Spain; -Sweden; -Switzerland; -United Kingdom; -United States

Tags: #internationaltax #taxtion #pe #oecd