The permanent establishment is an essential concept in International Tax Law. The traditional definition was based on the existence of a fixed place of business. At present, the new economy requires a change in the concept of permanent establishment. The topic of permanent establishment is based today on the so-called sufficient economic presence. The European Union is working on the definition of a permanent digital establishment.
{"title":"Permanent Establishment – New Concept","authors":"César García Novoa","doi":"10.36250/00749.42","DOIUrl":"https://doi.org/10.36250/00749.42","url":null,"abstract":"The permanent establishment is an essential concept in International Tax Law. The traditional definition was based on the existence of a fixed place of business. At present, the new economy requires a change in the concept of permanent establishment. The topic of permanent establishment is based today on the so-called sufficient economic presence. The European Union is working on the definition of a permanent digital establishment.","PeriodicalId":146621,"journal":{"name":"European Financial Law in Times of Crisis of the European Union","volume":"88 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"115863674","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The objective of this paper is the analysis of the influence of European Union legal regulations, as well as international tax law on the development of tax law applicable to holding companies. It is particularly relevant for entities – holding companies conducting cross-border operation within the European Union. Currently, international holding companies create their tax strategies using internal domestic legal reg ulations, EU tax law, and international tax law (based on numerous agreements on avoiding double taxation). This contributes to creating tax optimisation policies that frequently boil down to international tax avoidance. Undoubtedly, the judicial decisions of the Court of Justice of the European Union have also influenced the development of tax law applicable to holding companies. Due to the lack of harmonisation of tax law applicable to international holding companies, the Court of Justice endeavours to support the processes of standardisation of the tax systems that these entities are covered by.
{"title":"Taxation of Holding Companies in the Context of EU and International Tax Law","authors":"D. Gajewski","doi":"10.36250/00749.15","DOIUrl":"https://doi.org/10.36250/00749.15","url":null,"abstract":"The objective of this paper is the analysis of the influence of European Union legal regulations, as well as international tax law on the development of tax law applicable to holding companies. It is particularly relevant for entities – holding companies conducting cross-border operation within the European Union. Currently, international holding companies create their tax strategies using internal domestic legal reg ulations, EU tax law, and international tax law (based on numerous agreements on avoiding double taxation). This contributes to creating tax optimisation policies that frequently boil down to international tax avoidance. Undoubtedly, the judicial decisions of the Court of Justice of the European Union have also influenced the development of tax law applicable to holding companies. Due to the lack of harmonisation of tax law applicable to international holding companies, the Court of Justice endeavours to support the processes of standardisation of the tax systems that these entities are covered by.","PeriodicalId":146621,"journal":{"name":"European Financial Law in Times of Crisis of the European Union","volume":"354 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"1900-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"125777011","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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