Abstract:
As taxation across borders have become a significant event, this study therefore focusses
on the taxation of business profits within the context of cross border transactions, especially
with reference to permanent establishments. The study places emphasise on the various
requirements and variations of the permanent establishment concept as used and defined
in the OECD and UN Model Tax Convention respectively, by drawing comparisons between
the various requirements and also identifying variances.
The study concluded by suggesting that the UN Model Double Tax Conventions offers better
taxation of business profits from the perspective of developing countries, within the context
of taxing business profits through the use of permanent establishments.
