Taxing Permanent Establishments : Analysis of Article 7 Oecd Model Treaty

This special report, based upon R.K. Rawal's comprehensive guide The Taxation of Permanent Establishments: An International Perspective, focuses on the different approaches taken in major international economies when implementing Article 7 on the avoidance of double taxation. The topics covered are: the taxation of profits of Permanent Establishments (PE) in the country of residence, transactions between the head office and PE, treatment of PE expenses, apportionment of profits, intra-group purchasing, income from immoveable property, and defining business profits. The countries covered include India, China, US, France, Germany, Italy, the Netherlands, Spain, and the UK.