Die Betriebsstätte in Doppelbesteuerungsabkommen

The book The Permanent Establishment in Double Taxation Conventions deals with the income tax law issues of how the term permanent establishment is defined in the OECD and UN Model Tax Convention and what function the concept of permanent establishment has in the system of double taxation agreements. It offers both academics and practitioners a comprehensive overview of the current state of the discussion. The paper covers a wide range of topics and deals with three interwoven aspects of the problems of permanent establishments under treaty law: the history of the origin, the constituent elements of the definition of the term permanent establishment and the function of the permanent establishment in the treaty system. In addition, the work develops innovative legal policy reform proposals.