Control of Expenses Computed by Permanent Establishments under the OECD Model Agreement Antonio Faúndez Ugalde
SUMMARY This paper is concerned with the different aspects to be considered when controlling expenses computed by permanent establishments under the OECD model agreement and the taxation consequences arising from their examination, specifying each regulation governing the matter and considering especially the current observations and reserves of such international body’s member countries.
The Author: Lawyer, PhD in Law at the Pontificia Universidad Católica de Valparaíso; Master in Tax Management at the Pontificia Universidad Católica de Valparaíso; Bachelor in Legal and Social Sciences at the Universidad Arturo Prat de Iquique; Lawyer at the Examination Department of the Regional Directorate of Valparaíso of the Internal Revenue Service; Associate Professor of the Master in Tax Management at the Pontificia Universidad Católica de Valparaíso; Member of the Instituto Chileno de Derecho Tributario.