The permanent establishment concept under tax treaties and its implications for multinational companies
Nakayama, Aiko
(2012)
The permanent establishment concept under tax treaties and its implications for multinational companies.
Masters thesis, Institute of Advanced Legal Studies, School of Advanced Study.
This dissertation explores the concept and implementations in practice of permanent establishment(PE) introduced by Article 5 in the OECD Model Income Tax Treaty, highlighting the implications and ambiguities for multinational companies and nation state tax regimes.
Item Type | Thesis (Masters) |
---|---|
Additional Information | Masters dissertation (merit) - MA in Taxation (Law, Administration and Practice) (TAX) |
Keywords | Taxation - Law and legislation - United Kingdom, Taxation - Law and legislation, International tax treaties, Double Tax convention, Multinational companies, Permanent Establishment, Enterprise, Business, Business profits, International Trade, Profession, Vocation, Treaty Interpretation, OECD, Organisation for Economic Co-operation and Development |
Subjects | Law |
Divisions | Institute of Advanced Legal Studies |
Date Deposited | 08 Feb 2013 13:55 |
Last Modified | 05 Aug 2024 23:41 |
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