The Resource 2008 OECD Model : place of effective management - what one can learn from the history

2008 OECD Model : place of effective management - what one can learn from the history

Label
2008 OECD Model : place of effective management - what one can learn from the history
Title
2008 OECD Model : place of effective management - what one can learn from the history
Creator
Subject
Language
eng
Summary
In the 2008 Update of the OECD Model, the Commentary on Art. 4 (Residence) changed the meaning of "place of effective management", the corporate residence tie-breaker, by deleting the sentence that had been added in 2000. This suggests that there is considerable uncertainty about the meaning of the expression. This article examines the history of the provision that is now available, which confirms that there has been uncertainty from the beginning. The article concludes that perhaps the time has come to abandon the expression
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 63 (2009),
http://library.link/vocab/creatorName
Avery Jones, J.F
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • OECD Model
  • residence
  • place of effective management
Label
2008 OECD Model : place of effective management - what one can learn from the history
Instantiates
Publication
Label
2008 OECD Model : place of effective management - what one can learn from the history
Publication

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