The Attribution of Profits to Permanent Establishments

The Attribution of Profits to Permanent Establishments

Author: Raffaele Russo

Publisher: IBFD

Published: 2005

Total Pages: 488

ISBN-13: 907607884X

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"The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016