Template-Type: ReDIF-Article 1.0
Author-Name: Lyudmila V. Polezharova
Author-Email: mila-minfin@mail.ru
Author-Workplace-Name: The Ministry of Finance of the Russian Federation
Title: Theoretical Background for Definition of Profit of the Permanent Establishment in the Sphere of International Taxation
Abstract: In the article scientific research of the theoretical basis and foreign and russian experience of the definition of profit of the permanent establishment of foreign organizations as one of the basic fields for the international taxation is conducted. Based on this background the principles for the establishment of the explicit and stable complex of rules for taxation of foreign organizations in Russia in accordance with modern international standards and trends are proposed.
Classification-JEL:
Keywords: double taxation, profit of the permanent establishment of the foreign organization, functional and evidential analyses, Agreement for the avoidance of double taxation, hypothetical model of a «separate independent enterprise»
Journal: Finansovyj žhurnal — Financial Journal
Pages: 63-74
Issue: 2
Year: 2013
Month: June
File-URL: http://www.nifi.ru/images/FILES/Journal/Archive/2013/2/statii/2013_02_07.pdf
File-Format: Application/pdf
Handle: RePEc:fru:finjrn:130207:p:63-74