International taxation of permanent establishments/ principles and policy
Michael Kobersky
- Cambridge: Cambridge univrsity press, 2011.
- 459 p.
Cover; Title; Copyright; Contents; Abbreviations; 1 Introduction; 2 International taxation: policy and law; 3 Some shortcomings of the tax treaty system; 4 History of tax treaties and the permanent establishment concept; 5 The role of the OECD Model Tax Treaty and Commentary; 6 Defining the personality of permanent establishments under former Article 7 and the pre-2008 Commentary and the 2008 Commentary; 7 Intra-bank loans under the pre-2008 Commentary and 1984 Report; 8 Intra-bank interest under the 2008 Report.