Aspecte privind impozitarea veniturilor obţinute din exploatarea drepturilor de proprietate intelectuală prin intermediul unui sediu permanent
Aspects of taxing personal income from the exploitation of intellectual property rights through a permanent establishment
Author(s): Andreea Iuliana PrisacariuSubject(s): International Law, Law on Economics, EU-Legislation
Published by: Editura Universităţii »Alexandru Ioan Cuza« din Iaşi
Keywords: permanent establishment; income tax; intellectual property rights; nonresidents; royalties
Summary/Abstract: The production, distribution, and access to creative content are facilitated by the development and diversification of digital technologies. This necessitates clarification of certain aspects regarding the taxation of income derived from the exploitation of intellectual property rights. A permanent establishment is the place where a nonresident conducts their activities, either fully or partially. In this context, the permanent establishment represents the location where creative activities are carried out. In this study, we aim to highlight the main consequences related to the taxation of income derived from the exploitation of intellectual property rights when such income is obtained through a permanent establishment. We will analyze scenarios involving multiple states, including the state of residence and the state where the permanent establishment is located.
Journal: Analele Științifice ale Universităţii Alexandru Ioan Cuza din Iași, seria Ştiinţe Juridice
- Issue Year: LXX/2024
- Issue No: 3
- Page Range: 49-65
- Page Count: 17
- Language: Romanian