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

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


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.

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.


Item Type: Thesis (Masters)
Additional Information: Masters dissertation (merit) - 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, 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: Theses and Dissertations > Dissertation
IALS Students
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URI: http://sas-space.sas.ac.uk/id/eprint/4723
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