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The subject. The author examines the criteria of creation of service permanent establishment (PE) in Russia and possibility of creation of this type of PE in providing R&D services in Russia by foreign specialists.The aim of the paper is to confirm ...
E. A. Zakharov
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The Future of the Digital Permanent Establishment Concept: Challenges and Obstacles
Addressing the challenges and implications of taxing the digital economy through the concept of Digital Permanent Establishment [DPE] is the main focus of this article.
Tereza Homa
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Permanent Establishment in the Form of Dependent Agent in the Light of the Base Erosion and Profit Shifting Project [PDF]
The subject of the paper is an analysis of the issue of permanent establishment in the form of a dependent agent. The main purpose is to list the positive conditions leading to the setting up of a permanent establishment in the form of a dependent agent.
Agata Lipińska
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PERMANENT ESTABLISHMENT. THE CRISIS OF THE ARTICLE 5 OECD MC IN THE DIGITAL ECONOMY [PDF]
The rise of the digital economy, breaking with business models that require a physical presence to develop their activities, has dislodged the traditional concept of permanent establishment set out in Article 5 OECD MC.
Montserrat Hermosín Álvarez
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Tax Economic Analysis of the European Commission's Digital Service Tax Proposal
The European Commission proposes a new tax of 3% on union-level revenues to ensure that the member states of the European Union can get a fair share of the income of multinational digital companies.
Ali Çelikkaya
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NEW IN THE PRACTICE OF APPLYING INTERNATIONAL TAX RULES IN THE DIGITAL ECONOMY [PDF]
The article reveals the features of applying the new tax rules put forward in the digital economy, and the emergence of additional challenges to tax administrations.
Волова Лариса Ивановна
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The digitalisation of the economy has created a number of complex problems in the area of taxation. A majority of these problems relate to the issue of the distribution of taxing rights between states in the context of taxing income received as a result ...
K. Ponomareva
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Base erosion and profit shifting by Google and platform market competition in Korea [PDF]
The adoption of Google Taxes is often mentioned with respect to corporate taxes avoided for a MNE that does not have a permanent establishment in the domestic market.
Lee Taehee
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NGOs and the UN Security Council: Between informal reality and possibilities of formal interaction [PDF]
Following the end of the Cold War, non-governmental organizations (NGOs) took the initiative in their interactions with the UN Security Council. Since then, mechanisms for informal consultations between NGOs and the Security Council have been established.
Jelica Gordanić
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Service permanent establishment in international tax law
Przedmiotem analizy dokonanej w artykule jest instytucja zakładu, występująca na gruncie międzynarodowego prawa podatkowego. Celem artykułu jest natomiast przedstawienie wersji zakładu usługowego, opracowanych przez OECD i ONZ, a także analiza relacji ...
Woźniak, Tomasz
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