COMPARATIVE LEGAL ANALYSIS OF THE CONCEPT OF PERMANENT ESTABLISHMENT IN OECD AND UN MODEL ACTS
Journal Title: Порівняльно-аналітичне право - Year 2018, Vol 6, Issue
Abstract
The article analyzes the approaches to the interpretation of the concept of permanent establishment in model acts of the OECD and the UN. In this context, the author presents an analysis of the provisions on permanent establishment in the existing international double taxation treaties concluded by Ukraine. The results of the study can be used by entities within tax planning of foreign economic activity and assessing the risk of a permanent establishment creation.
Authors and Affiliations
А. Д. Шенгель
Keywords
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