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Article . 2019
License: CC BY
Data sources: ZENODO
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ZENODO
Article . 2019
License: CC BY
Data sources: Datacite
ZENODO
Article . 2019
License: CC BY
Data sources: Datacite
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Análisis histórico del concepto de establecimiento permanente en el artículo 5 del Modelo de Convenio OCDE

Authors: Pedrosa López, José Carlos;

Análisis histórico del concepto de establecimiento permanente en el artículo 5 del Modelo de Convenio OCDE

Abstract

This scientific publication delves into the concept of the permanent establishment in Article 5 of the latest OECD Model Tax Convention (2017). Using a legal methodology and stringent rigor, the author defines this legal institute by meticulously analysing its historical evolution. Subsequently, taking into account the proposals made in the OECD's Action Plan on Base Erosion and Profit Shifting, specifically in its Action 7 titled, Permanent Establishment Status, it delineates the new typology of permanent establishments incorporated into the OECD Model Convention. The permanent establishment is a tax concept that signifies the presence of a non-resident entity in the domestic economy of a country, and therefore, if allowed by domestic and agreed tax law, the State where it is located may tax the income attributable to it. For this reason, the relevance and timeliness of this article are undeniable, as it defines the new typology of this legal institute and analyses the tax consequences and implications for States.

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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
0
Average
Average
Average
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