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Gabor Baranyai
Intertax
Volume 42, Issue 6/7 (2014) pp. 470 – 480
https://doi.org/10.54648/taxi2014044
Abstract
This article discusses some of the international taxation aspects of cross-border short-term employment. The main aim of the article is to analyse how such employment can trigger source taxation, and to provide an assessment on the related theoretical and practical issues. The article provides an overview of the current OECD framework and also discusses the OECD's proposed approach related to the PE-concept. The author analyses the criticism of the current OECD Commentary, and provides its own view on matters related to the concepts of 'economic employer' and the risks related to PE exposure.
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