Transfer pricing, users participation and profit attribution to digital permanent establishments a case study Raffaele Petruzzi
By: Petruzzi, Raffaele
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Material type: 
ArticlePublisher: 2019Subject(s): ECONOMÍA DIGITAL | ESTABLECIMIENTO PERMANENTE | PRECIOS DE TRANSFERENCIA
In:
International Transfer Pricing Journal v. 26, n. 2, March / April 2019, p. 87-90Summary: The recent introduction into the tax legislations of some countries of the definitions of "digital" permanent establishments (PEs) will necessarily generate the issue of assessing how much profit to attribute to a digital PE. This significant issue is still open to discussion and interpretation. This article aims at illustrating the issue by means of a practical example, as well as by providing some preliminary solutions to the issue.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2019/2-2 (Browse shelf) | Available | ITPJ/2019/2-2 |
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Disponible únicamente en formato electrónico en la Biblioteca del IEF.
Resumen.
The recent introduction into the tax legislations of some countries of the definitions of "digital" permanent establishments (PEs) will necessarily generate the issue of assessing how much profit to attribute to a digital PE. This significant issue is still open to discussion and interpretation. This article aims at illustrating the issue by means of a practical example, as well as by providing some preliminary solutions to the issue.
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