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Permanent Establishments - A Planning Primer

Permanent Establishments - A Planning Primer

Hardcover

General Law

Currently unavailable to order

ISBN10: 9065447172
ISBN13: 9789065447173
Publisher: Kluwer Law International
Published: Mar 4 2002
Pages: 204
Weight: 1.09
Height: 0.72 Width: 6.46 Depth: 9.48
Language: English
This book is a comprehensive review of the tax treaty concept of a permanent establishment' from its origins in early Prussian and British tax law to its present manifestation in over 1250 bilateral income tax treaties written by two of the leading authors on the subject. The book covers both Anglo Saxon and civil law precedent, The OECD and US model treaties used in developed country treaties and the differing approach of the UN model for developing countries. The book exhanstively deals with all aspects of the fixed place of business' and dependent agency' permanent establishments and the exceptions for independent agents, permitted ancilliary activities and parent subsidiary relationships. The text integrates conceptual analyses and technical discussion with relevant tax planning opportunities, appropriately highlighted or diagrammed. A number of valuable tax planning techniques are presented which have not been previously discussed in any literature.

Also from

Williams, Robert L., III

Also in

General Law