International Taxation and Transactional Models

Manuel C. Solbach

Chapter 2 in International Business Transactions and Taxation, 2023, pp 5-17 from Springer

Abstract: Abstract Transactional models established in each specific company typically have developed with the company, the business, and their customers. Any desire for designing or changing them typically is rather low unless a benefit for the vendor or the customer arises. As a result, business practitioners and most commercially oriented business education normally do not spend too much time on them. The OECD initiative of 2015 changed that level of attention with regard to the taxation triggered by International Business Transactions: Definitions of “permanent establishments” (PE) have been revised and increase the risk of tax incompliance if international business transactions were not conducted in line with laws and regulations by all functions involved. Having identified such an imminent tax risk, company can pursue two routes: managing the permanent establishment or changing the transactional model. This chapter explores the cornerstones of tax regulations and builds the connection between international taxation and the transactional model implemented.

Date: 2023
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DOI: 10.1007/978-3-031-39240-5_2

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