Dotationskapital von Betriebsstätten im internationalen Steuerrecht

In recent years significant changes have been made with regard to the taxation of permanent establishments. The attribution of profits is based on the fiction that permanent establishments are distinct and separate entities. In this context capital has to be allocated to those permanent establishments. This work provides a detailed economic analysis with regard to different international and national approaches to dealing with this attribution. For this reason, OECD principles as well as the national tax regulations of Germany, the United Kingdom and the United States are examined. In accordance with this, methods of avoiding double taxation and possible improvements of administrative procedures will be discussed.