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Legal and practical jurisdiction over the party
liable for
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the
tax
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Difficulties of application of classical rules to avoid
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double taxation (principles of the origin, and
source)
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Determining nationality and tax residence
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Crisis of the idea of Permanent Establishment.
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Alternatives
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Allocation of Income to Permanent Establishments
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operating in a country
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Transfer Prices
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Specification of taxable income
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Treatment of royalties
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