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following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer … evolved over time. It provides how internationally accepted transfer pricing rules were applied immediately prior to the BEPS … avoidance and income shifting, including problems related to low tax entities with 'excessive capital'. Having described the pre-BEPS …
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Introduction -- Fundamentals and objective -- Source taxation of business profits according to the OECD model -- Source taxation of business profits from a national point of view of Germany, the US and the BRIC states -- Cross-country analysis of the OECD and national PE concepts and the rules...
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