RT Journal Article
T1 An opportunistic, and yet appropriate, revision of the source threshold for the twenty-first century tax treaties
A1 Escribano, Eva
AB The present paper aims to delve into one of the most thrilling debates set out by the Base Erosion and Profit Shifting (BEPS) Project (specifically Action 1): the reconsideration of the permanent establishment threshold.Without disregarding the fiscal interests that have undeniably boosted the reopening of the discussion, we prefer to question the appropriateness of the PE from a different perspective. First, we will analyse the theoretical principles that originally served to justify the PE threshold. Subsequently, we will demonstrate the obsolescence of the term &- as it currently stands &- as a result of the challenges posed by the so-called digital economy and in light of the aforementioned principles. Some proposals for the way forward will be briefly outlined.
PB Kluwer Law International
SN 0165-2826
YR 2015
FD 2015
LK https://hdl.handle.net/10016/22236
UL https://hdl.handle.net/10016/22236
LA eng
NO This research is integrated within the R+D Project DER2013-47912-P (‘Rethinking the structure and concepts of international tax law’)
DS e-Archivo
RD 1 sept. 2024