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Attributing Free Capital and Profit to Permanent Banking Establishments
Jönköping University, Jönköping International Business School, JIBS, Commercial Law.
2010 (English)Independent thesis Advanced level (degree of Master (One Year)), 20 credits / 30 HE creditsStudent thesis
Abstract [en]

By September 2010, in its ongoing effort to clarify the subject of taxing a permanent establishment, the OECD launched a new article 7 in its model tax convention together with a revised version of the report on the attribution of profits to permanent establishments. The article and the report contain a new order of taxation, where a permanent establishment should, in almost all aspects, be treated as a separate entity.

The question is if the new approaches, methods and solutions provided by the article and the report will prove effective against double taxation. The thesis has studied this by analysing and then comparing the OECD’s authorised approach with the relevant literature and the current practical situation.

The result of the thesis presents that there are problems with the approaches and methods, which in some situations will cause double taxation, not the least regarding allocation of Free Capital. The thesis also concludes that the way in which article 7 of the model tax convention tries to solve double taxation without unnecessary use of the mutual agreement procedure is flawed in relation to differences in national legislation.

Place, publisher, year, edition, pages
2010. , p. 66
Keyword [en]
Permanent Banking Establishment, Attribution of Profits, Transfer Pricing, Free Capital
National Category
Law (excluding Law and Society)
Identifiers
URN: urn:nbn:se:hj:diva-14007OAI: oai:DiVA.org:hj-14007DiVA, id: diva2:379857
Uppsok
Social and Behavioural Science, Law
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Examiners
Available from: 2010-12-29 Created: 2010-12-20 Last updated: 2010-12-29Bibliographically approved

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CiteExportLink to record
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Citation style
  • apa
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  • en-US
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