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Attribution of profits to permanent establishments under UK law – Inbound situations – (UK permanent establishment of a non-resident company)

Citation: Kepper, Philipp (2012) Attribution of profits to permanent establishments under UK law – Inbound situations – (UK permanent establishment of a non-resident company). Masters thesis, Institute of Advanced Legal Studies, School of Advanced Study.

Philipp_Kepper_MA_Taxation_dissertation.pdf

Creative Commons: Attribution-Noncommercial-No Derivative Works 3.0

This disseration examines past uncertainties and current practice determining the legal position in the United Kingdom on taxing the profits of non-UK resident companies trading through Permanent Establishments (PEs). The author looks at the way and the extent to which OECD Model Law has been implemented in the UK.

Additional Information: Masters dissertation (distinction) - MA in Taxation (Law, Administration and Practice) (TAX)
Creators: Kepper, Philipp and
Subjects: Law
Keywords: Taxation - Law and legislation - United Kingdom, Taxation - Law and legislation, International tax treaties, Double Tax convention, Business profits, Permanent Establishment, Treaty Interpretation, OECD, Organisation for Economic Co-operation and Development
Divisions: Institute of Advanced Legal Studies
Collections: Dissertation
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Dates:
  • 2012 (completed)

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