Results 11 to 20 of about 65,628 (266)

Permanent Establishment in the Form of Dependent Agent in the Light of the Base Erosion and Profit Shifting Project [PDF]

open access: yesSocietas et Iurisprudentia, 2021
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
doaj   +1 more source

Creation of service permanent establishment in Russian Federation when providing R&D services by foreign specialists

open access: yesПравоприменение, 2021
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
doaj   +1 more source

PERMANENT ESTABLISHMENT. THE CRISIS OF THE ARTICLE 5 OECD MC IN THE DIGITAL ECONOMY [PDF]

open access: yesCrónica Tributaria, 2021
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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NEW IN THE PRACTICE OF APPLYING INTERNATIONAL TAX RULES IN THE DIGITAL ECONOMY [PDF]

open access: yesСеверо-Кавказский юридический вестник, 2020
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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Tax Economic Analysis of the European Commission's Digital Service Tax Proposal

open access: yesInternational Journal of Public Finance, 2021
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
doaj   +1 more source

Base erosion and profit shifting by Google and platform market competition in Korea [PDF]

open access: yesSHS Web of Conferences, 2020
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
doaj   +1 more source

Tax Challenges Arising from the Digitalisation of the Economy: The Development of the OECD Project and Possible Implementation in Russia

open access: yesBRICS Law Journal, 2022
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
doaj   +1 more source

Tax treaty override in Slovakia - Digital platform permanent establishment

open access: yesBratislava Law Review, 2018
The article analyses the new “digital platform permanent establishment” concept as a legal fiction establishing a fixed place even in situations where there is no actual fixed place.
Tomáš Cibuľa, Matej Kačaljak
doaj   +1 more source

NGOs and the UN Security Council: Between informal reality and possibilities of formal interaction [PDF]

open access: yesThe Review of International Affairs, 2021
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
doaj   +1 more source

A critical analysis of the concepts ‘Permanent Establishment’ and ‘Foreign Business Establishment’

open access: yesJournal of Economic and Financial Sciences, 2012
The objective of this study was to analyse and compare the concepts permanent establishment and foreign business establishment in order to make recommendations regarding the required additions and amendments to replace the concept foreign business ...
Linda van Schalkwyk, Rozelle van Schaik
doaj   +1 more source

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