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E-commerce and source-based income taxation / Dale Pinto.

By: Pinto, Dale.
Contributor(s): International Bureau of Fiscal Documentation.
Material type: materialTypeLabelBookCall no.: KF6495.E45 P56 2003Series: Doctoral series: v. 6.Publication: Amsterdam : IBFD, c2003Description: xiv, 244 p.Notes: "Submitted in total fulfilment of the requirements of the degree of Doctor of Philosophy, March 2002, Faculty of Law, the University of Melbourne."; "NUR 826."ISBN: 9076078564; 9789076078564.Subject(s): Electronic commerce -- Taxation | Income tax -- Law and legislation | International economic relations
Contents:
1. Introduction -- 2. The Theoretical Foundations and Rationale for SourceBased Taxation -- 3. The Definition of Source and Identification of Characteristics of Electronic Commerce Which Suggest a Need to Reconceptualise the Way Source is Defined -- 4. The Need to Reconceptualise the Way Source is Defined for Active Business Profits under the Permanent Establishment Threshold -- 5. The Need to Reconceptualise the Way Source is Defined for Passive Income -- 6. Reconceptualising Source for Active and Passive Income - The Base Erosion Approach -- 7. Reconceptualising Source for Active and Passive Income - The Virtual Permanent Establishment Approach -- 8. Reconceptualising Source for Active and Passive Income – The Refundable with Holding Approach -- 9. Summary, Conclusions, Implementation of the Research and Future Outlook.
List(s) this item appears in: TULAW-New Book-2018-10-1-31 (foreign)
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"Submitted in total fulfilment of the requirements of the degree of Doctor of Philosophy, March 2002, Faculty of Law, the University of Melbourne."

"NUR 826."

Includes bibliographical references.

1. Introduction -- 2. The Theoretical Foundations and Rationale for SourceBased Taxation -- 3. The Definition of Source and Identification of Characteristics of Electronic Commerce Which Suggest a Need to Reconceptualise the Way Source is Defined -- 4. The Need to Reconceptualise the Way Source is Defined for Active Business Profits under the Permanent Establishment Threshold -- 5. The Need to Reconceptualise the Way Source is Defined for Passive Income -- 6. Reconceptualising Source for Active and Passive Income - The Base Erosion Approach -- 7. Reconceptualising Source for Active and Passive Income - The Virtual Permanent Establishment Approach -- 8. Reconceptualising Source for Active and Passive Income – The Refundable with Holding Approach -- 9. Summary, Conclusions, Implementation of the Research and Future Outlook.

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