Characterisation and Taxation of Cross-Border Pipelines

Characterisation and Taxation of Cross-Border Pipelines

This book provides an in-depth analysis of characterisation and taxation of pipelines, including the PE issue, allocation of income and the hierarchical ranking of sources.

• Introduction
• Characterisation
• The concept of international law and tax law
• Hierarchical ranking in international tax law
• Characterisation of a cross-border pipeline as preparatory or auxiliary character, immovable property, passive income or as other income
• Characterisation of cross-border pipelines as PE
• Allocation of income from pipelines for the different characterisations
• Conclusion and recommendations.

SummaryCharacterisation and Taxation of Cross-Border Pipelines provides a comprehensive analysis of the issues related to the taxation of cross-border pipelines. It offers solutions to the various tax issues that a cross-border pipeline might raise. The book concludes by recommending changes to the OECD Model Tax Treaty and its Commentaries to reduce uncertainty, avoid double taxation or less than a single taxation, and establish a more common international approach for the characterisation and taxation of cross-border pipelines and their allocation."-- Publisher description.