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Travellers, Tax Policy and Agency Permanent Establishments

British Tax Review, No. 6, pp. 538-553, 2010

Sydney Law School Research Paper No. 11/01

17 Pages Posted: 11 Jan 2011  

Richard J. Vann

The University of Sydney Law School

Date Written: January 10, 2011

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.

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

JEL Classification: K10, K30, K33, K34

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: https://ssrn.com/abstract=1737995

Richard J. Vann (Contact Author)

The University of Sydney Law School ( 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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