Cahiers de Droit Fiscal International - Volume LXXXIa - 1996 Principles for the Determination of the Income and Capital of Permanent Establishments and Their Application to Banks, Insurance Companies and Other Financial Institutions

This Volume deals with the taxation of permanent establishments of internationally operating banks and insurance companies. In particular, the determination of taxable income and capital under the various jurisdictions is discussed. Light is thereby shed upon special problems relating to banking and insurance companies, such as the applicable methods of apportionment of capital and income, expenses for head office services and their tax treatment, the treatment of the transfer of assests, as well as the treatment of interest and other financing charges and problems involving global trading activities.