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International Taxation of Permanent Establishments
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
Income Tax
This well respected text, now in its 9th edition, has been revised and updated to include the latest developments in taxation law.The company tax chapter comprehensively covers the taxation of companies, including the dividend imputation system and the carry-forward loss rules.The tax avoidance chapter includes recent case law.The deductions chapter incorporates recent case law on business deductions and deductions available to employees.The taxation of trusts chapter has been updated to include the most recent legislative changes in this area.The authors explain the principles of income tax law and other tax legislation. Commentary on the key tax concepts and extracts of leading cases illus...
Income Tax
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Income Tax
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Income Tax
This established text covering the major areas of taxaton has been fully revised to include the latest developments in taxation law. This 8th edition retains the strengths which have won it universal praise.
Income Tax
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Income Tax
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Taxation of Branches of International Banks
Examines the taxation of branches of international banks under the OECD Model Tax Treaty. Argues that globalisation has made the current international tax system obsolete and suggests that a multilateral tax treaty system is a twenty-first century solution.
Tax and Technology
The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, ind...
A Research Agenda for Tax Law
This Research Agenda considers the future direction of research in tax law, channeling creative thinking from leading tax scholars around the world who explore potential routes for further development in both traditional and more unconventional areas of tax law.
