Impact of OECD beps action 7 proposals on modification of articles 5(4), 5(5) and 5(6) of OECD model convention - an evaluation of action 7 on the future of intra-group transactions and business models of MNEs in their cross-border investments

• Main Authors: TAN, Ching Khee, SYRETT, Henry
• Format: text
• Language: English
• Published: Institutional Knowledge at Singapore Management University 2017
• Subjects: Corporate governance; director tenure; board tenure; board composition; board diversity; CEO turnover; restatemen; Accounting
• Online Access: https://ink.library.smu.edu.sg/soe_research/2387; https://ink.library.smu.edu.sg/context/soe_research/article/3390/viewcontent/SSRN_id2930136.pdf
• Institution: Singapore Management University

The notion of permanent establishment (PE) is one of the most important issues in treaty-based international fiscal law; it is perhaps the single most important and dynamic one, too. With openness in economies, globalisation and rapid development of e-commerce business models, there is a complete ch...