Application of International Tax Law to the Changed Organisational Structures
The objective of this chapter is to compile the issues in international company taxation resulting from the ICT-induced economic changes. Thus, each of the tax fields of international company taxation identified in chapter 4 as important in the age of ICT is assessed in light of the aforementioned evaluation criteria. Subsequent to the analysis of defining a company’s residence, the permanent establishment as the main tax attribute for business profits in the source country is examined. Afterwards, the allocation of the tax base between different taxable entities in different jurisdictions is evaluated. The analysis ends with the examination of the suitability of the residence and the source principle in the age of ICT.
KeywordsSource Country Transfer Price Double Taxation Auxiliary Activity Source Principle
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