Personengesellschaften im internationalen Steuerrecht ... - IIFS

Prof. Dr. Jürgen Lüdicke Masterstudiengang 2012/2013 - 9 -
Personengesellschaften im internationalen Steuerrecht
EXAMPLE 6 STATE R STATE P
B
A
P
ROYALTIES
Example 7: P is a partnership established in State P. A and B are P’s Partners who reside
in State R. P owns shares in X, a company that is a resident of State S. X pays a dividend
to P. State R and S treat P as a taxable entity while State P treats it as fiscally transparent.
EXAMPLE 7 STATE R STATE P STATE S
A
B
P
DIVIDENDS
COMPANY
X
Example 3: P is an entity established in State P. A and B are P’s partners who reside in
State R. States P and S both treat P as a transparent entity but State R treats it as taxable
entity. P derives business profits from State S that is not attributable to a permanent
establishment in State S.
EXAMPLE 3 STATE R STATE P STATE S
A
B
P
BUSINESS
PROFITS
(NO P.E.)
Example 9: P is a partnership established in State P. A and B are P’s partners who reside
in State R. P owns shares in X, a company that is a resident of State S. X pays a dividend
to P. State P and State S treat P as a taxable entity while State R treats it as fiscally
transparent.