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
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...
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Main Authors: | TAN, Ching Khee, SYRETT, Henry |
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Format: | text |
Language: | English |
Published: |
Institutional Knowledge at Singapore Management University
2017
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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 |
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Institution: | Singapore Management University |
Language: | English |
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