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Taxation of the ride-sharing economy source taxation through service permanent establishment provisions revisited : the case under the Argentine treaty network Guillermo O. Teijeiro and Juan Manuel Vázquez

By: Tejeiro, Guillermo O.
Contributor(s): Vázquez, Juan Manuel.
Material type: ArticleArticlePublisher: 2019Subject(s): ESTABLECIMIENTO PERMANENTE | IMPUESTOS | ATRIBUCIÓN DE BENEFICIOS | ECONOMÍA COLABORATIVA | ARGENTINA In: Bulletin for International Taxation v. 73, n. 12, December 2019, p. 667-682Summary: This article considers the extent to which the application of the treaty Service permanent establishment provision would permit the source taxation of business profits derived by foreign ride-sharing platforms. In particular, the recently issued preliminary opinions of the Argentine tax authorities in this respect and the resulting request for a mutual agreement procedure are examined.
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Resumen.

This article considers the extent to which the application of the treaty Service permanent establishment provision would permit the source taxation of business profits derived by foreign ride-sharing platforms. In particular, the recently issued preliminary opinions of the Argentine tax authorities in this respect and the resulting request for a mutual agreement procedure are examined.

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