International Taxation of Income from Services under Double Tax Conventions Development Practice and Policy 1st edition by Marta Castelon ISBN 9041195947 978-9041195944
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ISBN 10: 9041195947
ISBN 13: 978-9041195944
Author: Marta Castelon
The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services.
It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECDs Base Erosion and Pro t Shifting (BEPS) initiative.
With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality.
International Taxation of Income from Services under Double Tax Conventions Development Practice and Policy 1st Table of contents:
Chapter 1 Introduction
I Preliminary Considerations
1 Jurisdiction to Tax Income from the Provision of Services
2 Avoidance of Double or Multiple Taxation on Income from the International Provision of Services
2.1 Double Taxation Conventions
2.2 The Multilateral Instrument (MLI) Resulting from BEPS Action 15
2.2.1 Background: The OECD and G20 BEPS Project
2.2.2 Content, Functioning and Implementation of the MLI
2.2.3 The Status of the Explanatory Statement to the MLI
2.3 The Focus of the Present Research
II Services and the International Provision of Services
1 Definition of Services
2 Modes of Provision of International Services
2.1 The Modes of Provision of International Services According to GATS
2.2 The Modes of Provision of International Services for the Purposes of DTCs
2.3 Importance of Thinking in Terms of Forms of Market Access
2.3.1 In the Context of the GATS
2.3.2 In the Context of DTCs
2.3.3 Summary and Conclusion
III Research Questions
1 Why Do So Many DTC Articles Deal with Income from the Provision of Services?
2 Should the Distinction Between Business Profits, Income from Independent Personal Services, Employment Income and Fees for Technical Services Be Retained?
3 What Are the Origins of the Current DTC Provisions on Income from Entrepreneurial and Professional Services?
4 Do Legal or Economic Principles Provide an Answer as to the Division of the Right to Tax?
5 What Are the Challenges Presented by the Allocation of Taxing Rights over Income from Entrepreneurial, Professional, and Technical Services under the Model Conventions (MCs)?
IV Terminology
1 Other State, Source State, Non-residence State, Host State
2 Developed Versus Developing Countries
V Structure of the Book
Chapter 2 History of the Taxation of Income from Independent Services under Double Tax Conventions
I 1869 DTC Between Prussia and Saxony
1 Introductory Remarks
2 Overview of the Taxation of Income from the Provision of Enterprise Services under the DTC
3 The Fixed Trade (“Stehendes Gewerbe”) Concept from an Interpretative and a Tax Policy Point of View
3.1 Interpreting the Expression “Fixed Trade”
3.1.1 Meaning under Prussian Law
3.1.1.1 Was There a Force of Attraction for Fixed Trade?
3.1.2 Meaning under Saxon Law
3.1.3 Meaning under the 1869 Trade, Commerce and Industry Regulation Act of the North-German Confederation
3.1.4 Liberal Professionals: Neither Fixed nor Itinerant Traders
3.1.4.1 General Remarks
3.1.4.2 Historical Roots and Main Characteristics
3.1.4.3 Why Were Liberal Professions Neither Fixed Trade nor Itinerant Trade?
3.1.5 Comparing the Fixed Trade with the PE and the Fixed Base Thresholds
3.1.5.1 Thresholds in Comparison
3.1.5.2 Similarities Between Traders and Professionals
3.2 Why Was the Taxation of Income and Yields/Returns from the Provision of Services by Non-resident Foreigners Subject to the Fixed Trade Threshold?
3.2.1 Analysis of the Question from a Legal Perspective
3.2.1.1 Analysis of the Question from the Prussian Point of View
3.2.1.2 Analysis of the Question from the Saxon Point of View
3.2.1.3 Conclusion
3.2.2 Analysis of the Question from an Economic Perspective
II 1870 Law of the North-German Confederation on the Avoidance of Double Taxation (“Gesetz des Norddeutschen Bundes wegen Beseitigung der Doppelbesteuerung vom 13. Mai 1870”)
1 Introductory Remarks
2 Comparison with the 1869 Prussia-Saxony DTC with Regard to the Taxation of Income from Enterprise Services
3 The Concept of Carrying on a Trade from an Interpretative and a Tax Policy Point of View
3.1 Interpreting the Expression “Carrying on a Trade”
3.2 How Can the Move from the Fixed Trade (“stehendes Gewerbe”) Threshold to the Threshold of “Carrying on a Trade” (“Betrieb eines Gewerbes”) Be Explained?
3.2.1 Analysis of the Question from a Legal Perspective
3.2.2 Analysis of the Question from an Economic Perspective
3.2.3 Conclusion
III 1899 DTC Between Prussia and Austria-Hungary
1 Introductory Remarks
2 Comparison with the 1870 DTL
3 The PE (“Betriebsstätte”) Threshold from an Interpretative and a Tax Policy Point of View
3.1 Meaning of the Expression PE
3.2 Reasons for the Introduction of the PE Threshold
3.2.1 Analysis of the Question from a Legal Perspective
3.2.1.1 Prussian Trade Tax
3.2.1.2 Prussian Income Tax
3.2.1.3 Austrian Trade Tax
3.2.1.4 Austrian Income Tax
3.2.1.5 Conclusion
3.2.2 Analysis of the Question from an Economic Perspective
IV DTCs Between Other German States and Austria-Hungary at the Turn of the Twentieth Century
V 1909 German DTL (“Deutsches Doppelsteuergesetz”)
1 Introductory Remarks
2 Comparison with the 1870 DTL with Regard to the Taxation of Income from Enterprise Services
3 Conclusion
VI After the First World War: The Worldwide Treaty Practice, Drafts and Discussions Preceding the Release of the 1963 OECD Draft
1 The First Joint Attempts to Develop a Model DTC
1.1 The 1923 Report on Double Taxation by the Four Economists
1.1.1 Context
1.1.2 The Report
1.1.3 Critical Voices and Reasons for the Report’s Minor Impact on Practice
1.2 The Technical Experts’ 1925 Report
1.3 The 1927 Report of the Extended Committee
1.4 Further League of Nation’s Reports
2 The German Experience
2.1 National Laws on the Avoidance of Double Taxation Between the German States
2.1.1 Subjective Scope
2.1.2 The PE Threshold
2.1.2.1 Exclusion of Repositories
2.1.2.2 Introduction of the Construction PE, the Railway PE, and the Shipping PE
2.1.2.3 Exclusion of Pipelines in the Absence of Delivery of Gas, Water or Electricity
2.1.2.4 Comparative Table on the Evolution of the PE Concept under the German Legislation from 1899 to 1927
2.1.3 Itinerant Trade Activities and Peripatetic Storage Trade
2.1.4 Different Treatment of Trade Activities vis-à-vis Liberal Professions
2.1.5 Different Treatment of Trade Activities vis-à-vis Employment
2.2 National Provisions on Avoidance of International Double Taxation
2.3 German DTCs
2.3.1 Personal and Objective Scope
2.3.2 General Provisions on Taxation of Income from Enterprise Services
2.3.2.1 The PE
2.3.2.2 Itinerant and Peripatetic Trade
2.3.3 Liberal Professions
2.3.4 Employment Income
2.3.5 Income from Shipping and Air Transport
2.3.6 Directors’ Fees
3 The U.S. Experience
3.1 U.S. Unilateral Measures to Avoid International Double Taxation
3.2 U.S. DTCs
3.2.1 The 1932 DTC Between the United States of America and France
4 The Experience of Other European States and Their DTC Network
4.1 National Laws
4.2 DTCs
4.2.1 Personal and Objective Scope
4.2.2 General Provisions on Taxation of Income from Enterprise Services
4.2.2.1 PE
4.2.2.2 Itinerant and Peripatetic Trade
4.2.3 Liberal Professions
4.2.4 Employment Income
4.2.5 Income from Shipping and Air Transport
4.2.6 Director’s Fees
5 Mexico Draft DTC of 1943 and London Draft DTC of 1946
5.1 General Remarks
5.2 Personal and Objective Scope
5.3 General Provision Applicable to Income from Enterprise Services
5.3.1 PE
5.3.2 Itinerant Service Providers
5.4 Personal Services, Professional Services and Employment Income
5.5 Public Servants
5.6 Income from Shipping and Air Transport
5.7 Director’s Fees
5.8 Methods of Avoidance of Double Taxation
VII 1963 OECD Draft MC
1 General Remarks
2 Comparison Between the OECD Draft DTC of 1963 and the London Draft DTC of 1946 in Respect of Taxation of Income from Services Provisions
2.1 General Provision Applicable to Income from Enterprise Services
2.1.1 PE
2.1.2 Itinerant Service Providers
2.2 Professional Services
2.3 Employment Income
2.4 Public Servants
2.5 Shipping and Air Transport
2.6 Directors’ Fees
2.7 Artists and Athletes
VIII 1980 UN MC
1 Introductory Remarks
2 The Main Differences Between the UN MC of 1980 and the OECD MC of 1977
2.1 Extension of the Concept of PE
2.2 Introduction of the PE’s Limited Force of Attraction
2.3 Introduction of the Host State’s Right to Tax Profits from International Shipping Activities That Were Carried Out More than Casually in Its Territory
2.4 Widening of the Host State’s Right to Tax Income from Independent Personal Services
3 Conclusions
IX Conclusions from the Historical Analysis
1 Why Are There So Many DTC Articles Dealing with Income from the Provision of Services?
1.1 The Main Categories
1.1.1 Entrepreneurial Services and the PE Threshold
1.1.2 Income from Employment
1.1.2.1 Income from Private Employment
1.1.2.2 Income from Government Service
1.1.3 Liberal Professions
1.2 Itinerants and the Highly Mobile
1.2.1 Entertainers and Sportspersons
1.2.2 Shipping, Inland Waterways Transport and Air Transport
1.3 Similarity to Other Categories of Income
1.3.1 Directors’ Fees
2 Should the Distinction Between Business Profits, Income from Independent Personal Services, Employment Income and Fees for Technical Services Be Retained?
3 What Are the Origins of the Current DTC Provisions on the Allocation of Taxing Rights over Income from Entrepreneurial and Professional Services?
Chapter 3 Taxation of Income from Entrepreneurial, Professional, and Technical Services under the OECD MC, UN MC, U.S. MC and German MC
I Business Profits
1 Initial Remarks
2 Basic Rule PE
2.1 Initial Remarks
2.2 Fixed Place of Business
2.2.1 Place of Business
2.2.2 Right to Use Test
2.2.3 Instrumentality of the Place of Business
2.2.4 Geographical Meaning of “Fixed”
2.2.5 Temporal Meaning of “Fixed”
2.2.6 Productive Character of the Fixed Place of Business
3 Positive Catalogue
3.1 Examples of PEs or Rebuttable Presumptions of PEs?
3.2 Does the List Have an Exhaustive Character?
3.3 Applicability of the List to the Service Branch
4 Construction PE
4.1 Initial Remarks
4.2 Relationship Between Art. 5 (3) and Art. 5 (1)
4.3 Objective Scope of Art. 5 (3) in the Four Model DTCs Analyzed
4.4 Computation of a Project’s Duration
4.5 Subjective Scope of Art. 5 (3) and the Question of Subcontracting the Provision of Services
5 Construction PE after the Anti-BEPS Proposals
5.1 Principal Purpose Test
5.2 Provision Against the Splitting Up of Contracts
5.3 Definition of a Person Closely Related to an Enterprise
5.4 General Remarks
6 Negative List
6.1 Initial Remarks
6.2 Justification for Deeming a PE Not to Include Preparatory or Auxiliary Activities
6.3 Objective Scope
6.3.1 The Four Examples
6.3.2 General Clause
6.3.3 Combination of Preparatory and Auxiliary Activities
7 Negative List and the Anti-fragmentation Rules after the Anti-BEPS Proposals
7.1 Option A: Applicability of the “Preparatory or Auxiliary Requirement” to the Whole List
7.2 Option B: Deeming Some Activities to Have a Preparatory or Auxiliary Character Per Se
7.3 The Anti-fragmentation Rule
7.4 Possibilities of Making Reservations under the MLI
7.5 General Remarks
8 Agency PE
8.1 Initial Remarks
8.2 Evolution over the Years
8.3 Subjective Scope: Who Can Be Regarded as a Dependent Agent?
8.3.1 Independent Agent Exclusion
8.3.1.1 Ordinary Course of Business
8.3.1.2 Legal and Economic Independence
8.3.1.3 Dealing at Arm’s Length
8.3.2 Dependent Agent: Legal or Economic Dependency
8.4 Objective Scope
8.4.1 Habitual Exercise of the Authority to Conclude Contracts in the Name of the Foreign Enterprise
8.4.2 Commissionaire as a PE
8.4.2.1 Court Cases
8.4.2.2 Appraisal of the Court Decisions and Their Implications for the Taxation of Income from Enterprise Services
8.5 Consequences of Existence of an Agency PE
8.6 Agent Without Authority to Conclude Contracts Who Habitually Maintains a Stock of Goods or Merchandise
8.7 Conclusion
9 Agency PE after the Anti-BEPS Proposals
9.1 Broadening the Concept of Agency PE
9.2 Narrowing the Scope of the Independent Agent Provision
9.2.1 Exclusion of the Express Reference to Brokers and General Commission Agents
9.2.2 Deeming Agents Acting Exclusively or Almost Exclusively on Behalf of Closely Related Enterprises to Be Dependent
9.2.3 When Should an Agent Be Considered Independent
9.3 Possibility of Making Reservations under the MLI
9.4 General Remarks
10 Agency PE and Contracts for the Provision of Services
11 Anti-organ Clause and Subsidiaries as PEs
11.1 Origin of the Anti-organ Clause
11.2 Pre-requisites for a Subsidiary to Be Considered a PE of Its Parent
11.2.1 Appointment of Persons Conducting the Business of the Subsidiary by the Parent Company
11.2.2 “The Head and the Brain” (Management Director) of the Subsidiary Is an Employee (E.g. Vice-President) of the Parent Company
11.2.3 Parent Company Directs the Subsidiary, i.e., “Govern[s] the Adventure, Decide[s] What Should Be Done and What Capital Should Be Embarked in the Venture” of the Subsidiary. In Other Words, Parent Is in “Full Effectual and Constant Control” of the Subsidiary
11.2.4 Skill and Direction Through Which Profits Are Made by the Subsidiary Belong to the Parent Company
11.2.5 Business Scope of the Subsidiary Coincides with the Business Scope of the Parent Company
11.2.6 Premises of the Subsidiary Are at the Disposal of the Employees of the Parent Company
11.2.7 Subsidiary Has, in Fact, Authority to Legally and Economically Bind the Parent Company and Exercises This Authority Habitually
11.2.8 Employees of the Parent Company Are Seconded to the Subsidiary, but Continue to Be Remunerated by the Parent Company / Parent Company Reimburses the Costs of the Subsidiary, Including the Costs Caused by the Remuneration of Employees Seconded by the Parent Company to the Subsidiary
11.3 Consequences of the Re-characterization
12 Home Office as PE
13 Insurance PE
14 Services PE
14.1 From a Physical Presence Threshold to an Activities Threshold
14.2 Overview of the Services PE in the Model Conventions
14.2.1 UN MC: The First MC to Contain a Services PE Provision
14.2.2 The Introduction of Alternative Provisions in the 2008 OECD Model Commentary
14.2.3 The 2006 U.S. MC and the U.S.-Canada Services PE Provisions
14.2.3.1 Dudney Case: Inadequacy of the Fixed Base Threshold as an Argument for the Introduction of Services PE Rules in the U.S.-Canada DTC
14.2.3.2 Wolf Case: Difficulty in Distinguishing Dependent from Independent Provision of Services Points to Inadequacy of the Fixed Base Threshold
14.3 Project Services PE
14.3.1 Project Services PE under the UN MC
14.3.1.1 Requirements for the Existence of a Project Services PE under the UN MC
14.3.1.2 Consequences of the Existence of a Project Services PE under the UN MC
14.3.1.3 Relation Between Project Services PE and Construction PE under the UN MC
14.3.2 Project Services PEs under the OECD’s Alternative Provision
14.3.2.1 Requirements for Existence of a Project Services PE under the OECD’s Alternative Provision that Differ from Those of the UN Equivalent Provision
14.3.2.2 Consequences of the Existence of a Project Services PE under the OECD’s Alternative Provision
14.3.2.3 Relationship Between the OECD’s Alternative Provision on Project Services PE and the Construction PE
14.3.3 Project Services PE under the U.S.-Canada DTC
14.3.3.1 Requirements for Existence of a Project Services PE under the U.S.-Canada DTC
14.3.3.2 Consequences of the Existence of a Project Services PE under the U.S.-Canada DTC
14.3.3.3 Relationship Between Project Services PE and Construction PE under the U.S.-Canada DTC
14.3.4 Project Services PEs in Comparison
14.4 Individual Services PE
14.4.1 The UN Alternative Provision on Individual Services PEs
14.4.1.1 Subjective Scope of Application
14.4.1.2 Requirements for the Existence of an Individual Services PE under the UN Alternative Provision
14.4.1.3 Consequences of the Existence of an Individual Services PE under the UN Alternative Provision
14.4.1.4 Relationship Between the UN Alternative Provision on Individual Services PE and the Construction PE
14.4.2 The OECD’s Alternative Provision on Individual Services PE
14.4.2.1 Subjective Scope of Application
14.4.2.2 Requirements for Existence of an Individual Services PE under the OECD’s Alternative Provision
14.4.2.3 Consequences of the Existence of an Individual Services PE under the OECD’s Alternative Provision
14.4.2.4 Relationship Between the OECD’s Alternative Provision on Individual Services PE and the Construction PE
14.4.3 The Individual Services PE Rule under the U.S.-Canada DTC
14.4.3.1 Subjective Scope of Application
14.4.3.2 Requirements for Existence of an Individual Services PE under the U.S.-Canada DTC
14.4.3.3 Consequences of the Existence of an Individual Services PE under the U.S.-Canada DTC
14.4.3.4 Relationship Between the Individual Services PE and the Construction PE under the U.S.-Canada DTC
14.5 Conclusion
15 Server as a PE and Cloud Computing
15.1 Server as a PE in the Model Commentaries
15.2 Cloud Computing
15.3 Possible Measures to Allow the Host State to Tax Profits from the Digital Economy
15.3.1 Unilateral Measures to Tax Profits Arising from a Digital Presence
15.3.2 Proposals in the Context of the BEPS Project
15.3.3 Paper of the European Commission on the Taxation of the Digital Economy
15.3.4 The Proposed UN Article on Fees for Technical Services
15.3.5 Our Proposal
15.4 Conclusion
II Independent Personal Services
1 Introductory Remarks
2 Deletion of Art. 14 of the OECD MC
2.1 How Should the Deletion of Art. 14 Be Evaluated?
2.1.1 Neutrality Between Income from the Independent Provision of Personal Services and Business Profits
2.1.2 Neutrality Between Income from Independent Provision of Services and Employment Income
2.1.2.1 Alternative (a): Employment Income Is Subject Exclusively to the Thresholds Presently Applicable to Business Profits
2.1.2.2 Alternative (b): Business Profits Are Exclusively Subject to the Thresholds Currently Applicable to Dependent Personal Services
2.1.2.3 Alternative (c): Business Profits and Dependent Personal Services Are Both Subject to the Thresholds Presently Applicable Both to Business Profits and to Employment Income
3 Article 14 of the UN MC
3.1 Should Art. 14 of the UN MC Be Deleted?
3.1.1 Neutrality Between Income from the Independent Provision of Personal Services and Business Profits
3.1.1.1 In the Current Scenario
3.1.1.2 If Art. 14 of the UN MC Were Deleted
3.1.2 Neutrality Between Income from the Independent Provision of Services and Employment Income
3.1.2.1 In the Current Scenario
3.1.2.2 If Art. 14 of the UN MC Were Deleted
4 Current Importance of Art. 14
III Fees for Technical Services
1 Know-How and Technical Services under the MCs
1.1 Practical Consequences of Distinguishing Between Know-How and Services
1.2 How to Distinguish Between Know-How and Services
2 The Practice of Net Importers of Services and Technology
2.1 Host State’s Jurisdiction to Tax Royalty Payments
2.2 Inclusion of Fees for Technical Services and Technical Assistance Within the Royalties Article
3 Fees for Technical and Other Services in the UN Model Convention
3.1 Reasons Why It Is Planned to Introduce the Article
3.2 Structure and Content of the Article
3.2.1 Subjective Scope of Application
3.2.2 Division of the Right to Tax Between Residence and Host State
3.2.3 Applicable Rate of Host State Taxation
3.2.4 Relation to Other DTC Articles Dealing with Services
3.2.5 Definition of “Fees for Technical Services”
3.2.6 Arm’s Length Caveat
3.3 Critical Evaluation
IV Conclusions from the Analysis of the Current MCs
1 Should the Distinction Between Business Profits, Income from Independent Personal Services, Employment Income and Fees for Technical Services Be Retained?
2 What Are the Challenges Presented by the Allocation of Taxing Rights over Income from Entrepreneurial, Professional, and Technical Services under the MCs?
Chapter 4 Do Legal or Economic Principles Provide an Answer as to the Division of the Right to Tax?
I Equity: Allocation of the Right to Tax Between States and of the Tax Burden Between the Taxpayers
1 Inter-nation Equity
2 Inter-individual Equity
3 Economic Allegiance
3.1 Economic Allegiance as Implementation of Inter-nation Equity
3.2 Economic Allegiance as Implementation of Inter-individual Equity
3.3 Economic Allegiance as a Parameter for DTC Thresholds for Taxation of Income from Services
4 Benefit Principle
5 Ability to Pay
6 Source of Income
6.1 Source Versus Residence
6.2 Where Is the Source of Income?
6.3 Source Principle and the Taxation of Income from the International Provision of Services under the MCs
7 Base Erosion
8 BEPS
II Efficiency: Allocation of Capital, Persons and Services Between the States
1 Tax Neutrality in General
2 Tax Neutrality in International Tax Law: Capital as Factor
2.1 Capital Export Neutrality, Capital Import Neutrality, Capital Ownership Neutrality, National Neutrality
2.1.1 Overview
2.1.1.1 The View of Peggy B. Musgrave
2.1.1.2 Division of CIN into Savings Neutrality and CON
2.1.1.3 Preliminary Conclusions on the Use of CEN, CIN, CON, and National Neutrality as Benchmarks for the Division of the Right to Tax Income
2.1.2 In the Context of the International Provision of Services
2.1.2.1 Durable Physical Commercial Presence
3 Tax Neutrality in International Tax Law: Persons as a Factor
3.1 Durable Presence of Natural Persons
3.1.1 Normative Analysis
3.1.2 Are the Provisions of the Four MCs Analyzed in Line with the Results Achieved?
4 Tax Neutrality in International Tax Law: Services as a Factor
4.1 Temporary Presence of Legal Persons Through Employees or Other Personnel and Temporary Presence of Natural Persons
4.1.1 Normative Analysis
4.1.2 Are the Provisions of the Four MCs Analyzed in Line with the Results Achieved?
4.2 Remote Supply
4.2.1 Remote Provision Is Similar to Consumption Abroad
4.2.1.1 Normative Analysis
4.2.1.2 Are the Provisions of the Four MCs Analyzed in Line with the Results Achieved?
4.2.2 Remote Service Provider Is in a Comparable Position to Resident of the Host State with Respect to Level of Access to the Market
4.2.2.1 Normative Analysis
4.2.2.2 Are the Provisions of the Four MCs Analyzed in Line with the Results Achieved?
5 Summary and Suggestions de lege ferenda
III Conclusion
1 Should the Distinction Between Business Profits, Income from Independent Personal Services, Employment Income and Fees for Technical Services Be Retained?
2 Do Legal or Economic Principles Provide an Answer as to the Division of the Right to Tax?
Chapter 5 Conclusions
I Why Do So Many DTC Articles Deal with Income from the Provision of Services?
II Should the Distinction Between Business Profits, Income from Independent Personal Services, Employment Income and Fees for Technical Services Be Retained?
III What Are the Origins of the Current DTC Provisions on Income from Entrepreneurial and Professional Services?
IV Do Legal or Economic Principles Provide an Answer as to the Division of the Right to Tax?
V What Are the Challenges Presented by the Allocation of Taxing Rights over Income from Entreprene
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