Abstract

http://ssrn.com/abstract=1737995
 
 

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Travellers, Tax Policy and Agency Permanent Establishments


Richard J. Vann


University of Sydney - Faculty of Law

January 10, 2011

British Tax Review, No. 6, pp. 538-553, 2010
Sydney Law School Research Paper No. 11/01

Abstract:     
This article analyses the policy, historical development and current application of permanent establishment rules for travellers. It is readily accepted that pedlars and itinerant merchants do not give rise to permanent establishments but after many years of the agency permanent establishment rules apparently requiring that the agent have a fixed place of business in the country concerned, the OECD has recently concluded to the contrary for travelling salesmen. The article argues that the OECD should have followed the historical trend as that matches the OECD’s proclaimed policies for adopting the permanent establishment as the international threshold for taxing business income more closely.

Number of Pages in PDF File: 17

Keywords: OECD, agents, foreign travel, permanent establishment, tax principles, travellers

JEL Classification: K10, K30, K33, K34

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Date posted: January 11, 2011  

Suggested Citation

Vann, Richard J., Travellers, Tax Policy and Agency Permanent Establishments (January 10, 2011). British Tax Review, No. 6, pp. 538-553, 2010; Sydney Law School Research Paper No. 11/01. Available at SSRN: http://ssrn.com/abstract=1737995

Contact Information

Richard J. Vann (Contact Author)
University of Sydney - Faculty of Law ( email )
Faculty of Law Building, F10
The University of Sydney
Camperdown, NSW 2006
Australia
+61 2 9351 0206 (Phone)
+ 61 2 9351 0200 (Fax)
HOME PAGE: http://www.law.usyd.edu.au/about/staff/RichardVann/index.shtml
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