Permanent establishment thesis

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From: Eric L.
Category: argument lang
Added: 14.04.2021
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Permanent Establishment within the Digital Economy

The Anti-Abuse Rule for Permanent Establishments Situated in Third States - IBFD

The on- going tax challenges raised by the digital economy emphasize the fundamental tax pol- icy issues. These developments, which relate mostly to the terms nexus and profit allocation under international tax law, may affect many MNEs respectively their businesses. The key objectives of this Master Thesis is to outline the impact respectively chal- lenges of the proposed new digital PE concept, notably on Swiss headquartered MNEs and to derive recommendations and potential solutions for these enterprises from a consulting standpoint. While the traditional PE concept is relatively old, the application is more complex as businesses become increasingly digitalized and countries around the globe are intro- ducing unilateral measures. Swiss MNEs thus should thoroughly evaluate their intra- group structures and ensure their business models are in line with their transfer pricing documentation to mitigate any tax and transfer pricing exposure.

Digital Permanent Establishments

The impact of e-commerce on the permanent establishment definition Login. JavaScript is disabled for your browser. Some features of this site may not work without it. The main object of the concept of the definition of a permanent establishment in a double tax agreement is to set out the type and permanency of business activities that an entity must conduct before they can be subject to tax in another jurisdiction. Furthermore, the definition of a 'permanent establishment' as defined in article 5 of the OECD model tax convention requires the existence of a fixed place of business.
Student thesis : Master thesis. In recent years, global revenues in the digital economy have grown exponentially. Companies operating across borders no longer need a physical place of business to sell products and provide services to foreign customers. With new technologies, companies can now do business with customers geographically located in other countries without having a physical presence in a given country and without being subject to local taxation. Current legislation and bilateral conventions preventing double taxation often results in taxation of income in the country of corporate domicile, thus basing the assessment of where to tax income on purely physical factors.

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