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The New Permanent Establishment
This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.
He Looks So Fine: Part Two
"The first time Alberto watched a revenge flick, he was so mesmerised; he discovered something about himself: if the retaliation in the second half of the movie was satisfactory enough, there was no amount of abuse he couldn’t stomach in the first half. Catharsis, he found out it was called. Alberto was fond of that word. Catharsis." ♥ After spending the Christmas holidays together, Mathias and Alberto return to school disenchanted, and convinced of the other’s indifference. When they both find themselves in detention, they decide to skip school together, consequences be damned. But as they are inexorably pulled toward each other, their personal demons are working their hardest to keep...
All Our Wars
For fans of Katie Gutierrez’s More Than You'll Ever Know and Netflix’s Narcos comes a high-stakes thriller about the daughter of a high-ranking Mexican cartel leader dragged back to the life she fought hard to escape. Twelve years have passed since Sofia De Luna’s mother was murdered. Sofia now leads a quiet life in Chicago, far from the cartel violence she was raised amidst. But when her narco father’s retirement catapults her to head of the family, that peaceful existence is upended. Unhappy with this changeover of power, Sofia’s brothers and cousins are wary of her desire to legitimize the family and her insistent questions about her mother’s mysterious death. Meanwhile, in Me...
The Atheneum
None
The Attribution of Profits to Permanent Establishments
This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries. The book begins by examining how the dealings between a permanent establishment and the enterprise of which it is a part should be treated for tax treaty purposes. An overview of the historical development of Article 7 of the OECD Model Convention is provided, starting with the Draft Conventions prepared by the League of Nations up to the current OECD Model and Commentary, and taking into account the recent OECD Discussion Drafts. A comparative survey is presented in which the tax consequences of dealings between different parts of the same enterprise are analyse...
