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The permanent establishment concept under tax treaties and its implications for multinational companies

Citation: Nakayama, Aiko (2012) The permanent establishment concept under tax treaties and its implications for multinational companies. Masters thesis, Institute of Advanced Legal Studies, School of Advanced Study.

Aiko_Nakayama_MA_Taxation_dissertation.pdf

Creative Commons: Attribution-Noncommercial-No Derivative Works 3.0

This dissertation explores the concept and implementations in practice of permanent establishment(PE) introduced by Article 5 in the OECD Model Income Tax Treaty, highlighting the implications and ambiguities for multinational companies and nation state tax regimes.

Additional Information: Masters dissertation (merit) - MA in Taxation (Law, Administration and Practice) (TAX)
Creators: Nakayama, Aiko and
Related URLs:
Subjects: Law
Keywords: Taxation - Law and legislation - United Kingdom, Taxation - Law and legislation, International tax treaties, Double Tax convention, Multinational companies, Permanent Establishment, Enterprise, Business, Business profits, International Trade, Profession, Vocation, Treaty Interpretation, OECD, Organisation for Economic Co-operation and Development
Divisions: Institute of Advanced Legal Studies
Collections: Dissertation
IALS Students
Dates:
  • 2012 (submitted)

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