The Concept of Permanent Establishment in the Insurance Business



By: Daniele Frescurato

ISBN: 9789403532837

Published:22 Apr 2021


The Concept of Permanent Establishment in the Insurance Business is a trailblazing book focusing on the issues that the insurance companies encounter concerning a permanent establishment, providing an in-depth analysis of how the concept is applied in the context of the insurance industry and further considering potential changes to the permanent establishment definition contained in tax treaties to reflect specific features of this industry. The models commonly used to negotiate bilateral tax treaties say very little about the insurance industry and how the dependent agent permanent establishment provision may affect cross-border marketing, promotion, and insurance distribution.


What’s in this book:


The study furnishes an analytical framework of the insurance industry (particularly, its regulatory landscape and value chain) and advances to discuss the following aspects systematically:


-       comprehensive analysis of the dependent agent permanent establishment provision as laid down in model tax treaties and related commentaries;

-       assessment of the existence of a dependent agent permanent establishment in the context of the most common business models adopted by insurance companies; and

-       comparative analysis of double tax treaty policies adopted in several countries for the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes.


The author concludes by proposing changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries tailored to how insurance companies conduct their business in countries other than incorporation.


How this will help you:


As a pivotal and pertinent contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove especially valuable to practitioners in international tax and insurance law, professionals in the financial services sector, and tax academics.


 Table Of Contents:

About the Author


List of Abbreviations


Preliminary Remarks


Overview of the Insurance Business


Analysis of the Double Tax Treaty Law


Analysis of the Insurance Business Models


Analysis of the Swiss Double Tax Treaty Policy


Assessment of the Existing Rules and Reform Proposals


Concluding Remarks




Disclaimer: This title is in pre-production and any names, credits or associations are subject to change. The current table of contents and subject matter is for pre-release sample purposes only.

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