1. Introduction; 2. International tax: policy and law; 3. Some shortcomings of the tax treaty system; 4. History of tax treaties and the permanent establishment concept; 5. The role of the OECD model and commentary; 6. Defining the personality of permanent establishments under Article 7 and the pre-2008 commentary and 2008 commentary; 7. Intra-bank interest under the pre-2008 commentary and 1984 report; 8. Intra-bank interest under the 2008 commentary and the 2008 report; 9. Business restructuring involving permanent establishments and the OECD transfer pricing methods; 10. New Article 7 of the OECD model and commentary; 11. Unitary taxation; 12. Conclusion.
This book analyses the principles for attributing profits to branches of multinational enterprises for tax purposes under the OECD Model Tax Convention.
Michael Kobetsky teaches and researches in the fields of taxation law and international tax law at the Melbourne Law School, University of Melbourne.