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

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


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.

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.


Item Type: Thesis (Masters)
Additional Information: Masters dissertation (distinction) - MA in Taxation (Law, Administration and Practice) (TAX)
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: Theses and Dissertations > Dissertation
IALS Students
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URI: http://sas-space.sas.ac.uk/id/eprint/4722
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