A NEW INTERNATIONAL APPROACH ON PREVENTING THE ARTIFICIAL AVOIDANCE OF PE STATUS
Abstract
In the recent times, we are witnessing a period in which international tax issues are deeply discussed than ever before. Excessive base erosion and profit shifting (initiatives) as a consequence of weakness and problems in existing international tax rules have played a significant role in increasing focus on international tax issues. Recently, the concept of Permanent Establishment which is a significant criteria in determining taxing right of source state in tax treaties has been abused and frequently used for tax avoidance. With globalization, the emergence of new business models as a result of stunning developments in digital technologies have allowed commercial actives to be conducted relatively easier compared to past without a workplace (physical presence). In this context, the necessity to review definition of Permanent Establishment which is considered as a global taxation problem is emphasized concretely in Action Plan on Base Erosion and Profit Shifting which was prepared by OECD and endorsed in G20 summit in 2013 September at Saint-Petersburg. “Preventing the Artificial Avoidance of Permanent Establishment Status” composes Action 7 of the Plan and as a result of works under this action item, its final report was published in 2015 October. In this article, problems regarding this issue and developed recommendations within the context of G20/OECD Action Plan will be evaluated.
Keywords
References
- Action 7: Final Report, Preventing the Artificial Avoidance of Permanent
- Establishment Status, OECD. Erişim: http://www.oecd.org/ctp/
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- 7-2015-final-report-9789264241220-en.htm (07/04/2016)
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Details
Primary Language
English
Subjects
-
Journal Section
Research Article
Publication Date
March 17, 2017
Submission Date
March 17, 2017
Acceptance Date
June 28, 2016
Published in Issue
Year 2017 Volume: 10 Number: 1
Cited By
MATRAH AŞINDIRMA VE KÂR KAYDIRMA PROJESİ’NDE GELİNEN AŞAMA VE KAZANIMLAR
Anadolu Üniversitesi İktisadi ve İdari Bilimler Fakültesi Dergisi
https://doi.org/10.53443/anadoluibfd.1441791
