The Attribution of Profits to Permanent Establishment The Taxation of Intra-company Dealing

The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries. This book is essential reading for anyone dealing with PEs in their daily practice, including tax advisers, tax lawyers, tax authorities and accountants. Academics and students will also benefit from the insights contained in this book.