The Resource A construction consortium as a permanent establishment from an international tax law perspective : inconsistencies and deficiencies in Article 5(3) of the OECD Model and Commentary

A construction consortium as a permanent establishment from an international tax law perspective : inconsistencies and deficiencies in Article 5(3) of the OECD Model and Commentary

Label
A construction consortium as a permanent establishment from an international tax law perspective : inconsistencies and deficiencies in Article 5(3) of the OECD Model and Commentary
Title
A construction consortium as a permanent establishment from an international tax law perspective : inconsistencies and deficiencies in Article 5(3) of the OECD Model and Commentary
Creator
Subject
Language
eng
Summary
In this article, the author considers key difficulties in the interpretation and application of article 5(3), in conjunction with article 7, of the OECD Model regarding the taxation of a non-resident investor forming a joint-venture with a resident enterprise to undertake a substantial construction or infrastructure project in the latter's residence state
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 66 (2012),
http://library.link/vocab/creatorName
Lewicki, T
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • PE
  • OECD Model
  • treaty interpretation
  • construction project
Label
A construction consortium as a permanent establishment from an international tax law perspective : inconsistencies and deficiencies in Article 5(3) of the OECD Model and Commentary
Instantiates
Publication
Label
A construction consortium as a permanent establishment from an international tax law perspective : inconsistencies and deficiencies in Article 5(3) of the OECD Model and Commentary
Publication

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