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International Taxation of Permanent Establishments : Principles and Policy
Business restructuring involving permanent establishments and the OECD transfer pricing methods
monograph
Author(s):
Michael Kobetsky
Publication date
(Online):
2011
Publisher:
Cambridge University Press
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There is no author summary for this book yet. Authors can add summaries to their books on ScienceOpen to make them more accessible to a non-specialist audience.
Related collections
NeuroImaging Methods
Author and book information
Book Chapter
Pages
: 316-350
DOI:
10.1017/CBO9780511977855.010
SO-VID:
3e805758-12fc-4c58-910d-3e54105b425a
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Book chapters
pp. vi
Abbreviations
pp. 1
Introduction
pp. 11
International taxation: policy and law
pp. 65
Some shortcomings of the tax treaty system
pp. 106
History of tax treaties and the permanent establishment concept
pp. 152
The role of the OECD Model Tax Treaty and Commentary
pp. 179
Defining the personality of permanent establishments under former Article 7 and the pre-2008 Commentary and the 2008 Commentary
pp. 238
Intra-bank loans under the pre-2008 Commentary and 1984 Report
pp. 276
Intra-bank interest under the 2008 Report
pp. 316
Business restructuring involving permanent establishments and the OECD transfer pricing methods
pp. 351
New Article 7 of the OECD Model and Commentary
pp. 393
Unitary taxation
pp. 430
Conclusion
pp. 436
Bibliography
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