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Project

The taxation of permanent establisments: a critical analysis of the Authorized OECD approach and it's implications for Belgian tax practice.

The historical evolution of art. 7 of the OECD Model demonstrates that it is extremely difficult to define clear and appropriate principles underlying the tax treatment of a PE. The inconsistent interpretation of art. 7 of the 2005 OECD Model by different contracting states, was the immediate cause for the introduction of the Authorized OECD Approach (AOA). According to the OECD the AOA constitutes the preferred approach for attributing profits to a PE.  </>It is however questionable whetherthe AOA will reach the objectives it set out to achieve. The AOA raisesmany questions both from an international tax law and a Community law perspective. The main objective of this research project is to adress these questions. Having regard to the inactivity of the Belgian legislator on this subject, the research will subsequently assess the implications of the AOA for Belgian tax practice.</>
Date:24 Nov 2009 →  15 Mar 2016
Keywords:Income, Taxation
Disciplines:Law
Project type:PhD project