Permanent Establishments in International and EU Tax Law

Taxation of Permanent Establishments in global cross-border situations

The concept of permanent establishment is a cornerstone of international tax law. The authors, all graduates of the postgraduate program in International Tax Law at the Vienna University of Economics and Business (WU Wien), analyze this concept in detail. The contributions focus on the permanent establishment definition under Article 5 OECD Model Convention, the attribution of profits to permanent establishments under Article 7 OECD Model Convention, and permanent establishment issues arising under EU tax law.