Asset allocation to bank permanent establishments the German perspective Christian Engelen and Vassil Tcherveniachki
By: Engelen, Christian
.
Contributor(s): Tcherveniachki, Vassil.
Material type: 
ArticlePublisher: 2019Subject(s): BANCOS | ESTABLECIMIENTO PERMANENTE | IMPUESTOS | PRINCIPIO DE PLENA COMPETENCIA | ALEMANIA
In:
International Transfer Pricing Journal v. 26, n. 5, September / October 2019, p. 353-357Summary: There are special regulations covering the determination of profits and, thus, the taxation of bank permanent establishments in Germany. Mainly, these rules relate to the determination of the key entrepreneurial risk-taking function and, consequently, the allocation of assets. Given that the rules are largely pro-fiscal and not always in conformity with the arm's length principle, double taxation may result.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Recursos electrónicos | IEF | IEF | ITPJ/2019/5-10 (Browse shelf) | Available | ITPJ/2019/5-10 |
Browsing IEF Shelves Close shelf browser
Disponible únicamente en formato electrónico.
Resumen.
There are special regulations covering the determination of profits and, thus, the taxation of bank permanent establishments in Germany. Mainly, these rules relate to the determination of the key entrepreneurial risk-taking function and, consequently, the allocation of assets. Given that the rules are largely pro-fiscal and not always in conformity with the arm's length principle, double taxation may result.
Click on an image to view it in the image viewer
There are no comments for this item.