Taxation of Cross-border Services

Series on International Taxation Volume 47

Building on a detailed analysis of the OECD and the UN tax treaty models as regards taxation of cross-border services and#8211; their shortcomings as well as their efficacy and#8211; this immensely informative and practical book responds knowledgeably and precisely to such questions as the following:

• What are the provisions for Service PEs in the UN and OECD models and commentary?

• What is the distinction between and#8216;feesand#8217; and and#8216;fees for technical servicesand#8217;?

• How do the Articles dealing with and#8216;fees for technical serviceand#8217;, and#8216;permanent establishmentand#8217;, and and#8216;independent personal servicesand#8217; interact with each other?

The author spares no pains to convey clearly the implications of such crucial terms as and#8216;make availableand#8217;, and#8216;effectively connectedand#8217;, and and#8216;attributable toand#8217;. He also shows how revisions in service rules from scores of specific bilateral tax treaties from all over the world presage the emergence of a new global regime, and how Indiaand#8217;s new role as the worldand#8217;s most significant service economy has led it to become the major source of guidance in the law of cross-border taxation. Tax lawyers and consultants and corporate tax advisers everywhere will benefit hugely from this book as they consult it regularly for fast and reliable information and guidance. Government officials and academics in the field will also find here an incomparable resource for understanding how both authorities and businesses are coping with the intricacies of taxation of cross-border services.