The Taxation of Permanent Establishments

This book provides a comprehensive analysis of the rules governing the taxation of permanent establishments as implemented in the OECD Model Tax Convention and German national tax law. Deviations between the OECD approach and the German approach are identified and modifications to the rules as a result of the Base Erosion and Profit Shifting (BEPS) project are examined. Moreover, challenges imposed to the PE concept as a result of the digitalisation of the economy are identified and discussed. Against this background, the Pillar One Blueprint proposing a long-term solution to overcome the tax challenges arising from the digitalisation of the economy is presented and assessed against widely accepted overarching principles of tax policy.

Autorentext

Sven Hentschel is a research associate at the Chair of Business Taxation (Prof. Dr. Gerhard Kraft) at the Martin-Luther-University Halle-Wittenberg. His research focuses on international business taxation and transfer pricing.

Inhalt
Fundamentals of the Taxation of Permanent Establishments.- The Attribution of Profits to Permanent Establishments.- Digitalisation of the Economy and Its Implications for the PE Concept.- Adapting the International Corporate Tax System to the Digitalisation of the Economy.