Book contents
- Frontmatter
- Contents
- Abbreviations
- 1 Introduction
- 2 International taxation: policy and law
- 3 Some shortcomings of the tax treaty system
- 4 History of tax treaties and the permanent establishment concept
- 5 The role of the OECD Model Tax Treaty and Commentary
- 6 Defining the personality of permanent establishments under former Article 7 and the pre-2008 Commentary and the 2008 Commentary
- 7 Intra-bank loans under the pre-2008 Commentary and 1984 Report
- 8 Intra-bank interest under the 2008 Report
- 9 Business restructuring involving permanent establishments and the OECD transfer pricing methods
- 10 New Article 7 of the OECD Model and Commentary
- 11 Unitary taxation
- 12 Conclusion
- Bibliography
- Index
Index
Published online by Cambridge University Press: 07 September 2011
Book contents
- Frontmatter
- Contents
- Abbreviations
- 1 Introduction
- 2 International taxation: policy and law
- 3 Some shortcomings of the tax treaty system
- 4 History of tax treaties and the permanent establishment concept
- 5 The role of the OECD Model Tax Treaty and Commentary
- 6 Defining the personality of permanent establishments under former Article 7 and the pre-2008 Commentary and the 2008 Commentary
- 7 Intra-bank loans under the pre-2008 Commentary and 1984 Report
- 8 Intra-bank interest under the 2008 Report
- 9 Business restructuring involving permanent establishments and the OECD transfer pricing methods
- 10 New Article 7 of the OECD Model and Commentary
- 11 Unitary taxation
- 12 Conclusion
- Bibliography
- Index
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- International Taxation of Permanent EstablishmentsPrinciples and Policy, pp. 454 - 459Publisher: Cambridge University PressPrint publication year: 2011