Martin, Céline
Arm's length principle from a Swiss perspective profit allocation to inbound and outbound permanent establishments / Céline Martin, Vikram Chand & Natassia Burkhalter .-- , 2022
Resumen.
The article discusses the application of the arm's length principle from a Swiss tax treaty and Swiss national law perspective as applicable to transactions among separate entities as well as to head office and permanent establishment (PE) relations. It provides an overview of the profit allocation rules applicable in domestic and international cases. Moreover, for illustration, two case studies are developed and analysed for cross-border relations with fixed place PEs (inbound and outbound cases) and an example is provided for the interaction between international and domestic profit allocation.
ESTABLECIMIENTO PERMANENTE
IMPUESTOS
PRINCIPIO DE PLENA COMPETENCIA
SUIZA
Chand, Vikram
Burkhalter Martínez, Natassia
Intertax 0165-2826v. 50, issue 1, January 2022, p. 66-81
Arm's length principle from a Swiss perspective profit allocation to inbound and outbound permanent establishments / Céline Martin, Vikram Chand & Natassia Burkhalter .-- , 2022
Resumen.
The article discusses the application of the arm's length principle from a Swiss tax treaty and Swiss national law perspective as applicable to transactions among separate entities as well as to head office and permanent establishment (PE) relations. It provides an overview of the profit allocation rules applicable in domestic and international cases. Moreover, for illustration, two case studies are developed and analysed for cross-border relations with fixed place PEs (inbound and outbound cases) and an example is provided for the interaction between international and domestic profit allocation.
ESTABLECIMIENTO PERMANENTE
IMPUESTOS
PRINCIPIO DE PLENA COMPETENCIA
SUIZA
Chand, Vikram
Burkhalter Martínez, Natassia
Intertax 0165-2826v. 50, issue 1, January 2022, p. 66-81