International Company Taxation in the Era of Information and Communication Technologies: Issues and Options for Reform

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Anne Schafer presents proposals for the reform of the definition of a company’s residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.