Research on the Permanent Establishment Principle in International Tax Treaties

Author: Zhu Yansheng
Publisher:
Publish Date: 2006-09-01
Features: Except for the introduction and conclusion, this book is divided into seven chapters to explore the Permanent Establishment Principle:
Chapter 1 provides a comprehensive examination of the historical development of the "Permanent Establishment" concept.
Chapter 2 discusses the essence of place-based Permanent Establishments, focusing on the precise meaning of fixed places of business as the core elements constituting them.
Chapter 3 analyzes the essence of agency-based Permanent Establishments, focusing on the tax law significance of business agents as the core elements constituting them.
Chapter 4 primarily examines how to apply the Permanent Establishment determination standards discussed in Chapters 2 and 3 when enterprises conduct their specific business activities, for the identification of place-based and agency-based Permanent Establishments.
Chapter 5 discusses the concept of profit attribution of Permanent Establishments.
Chapter 6 explores the applicability of traditional Permanent Establishment principles in cross-border e-commerce activities.
Chapter 7 is a discussion on the practical application of the Permanent Establishment principle in China's international taxation activities.
—Zhu Yansheng