The Resource Interruptions in building site permanent establishments to be interpreted under the limited inclusion theory

Interruptions in building site permanent establishments to be interpreted under the limited inclusion theory

Label
Interruptions in building site permanent establishments to be interpreted under the limited inclusion theory
Title
Interruptions in building site permanent establishments to be interpreted under the limited inclusion theory
Creator
Subject
Language
eng
Summary
In this article, the author examines how article 5(3) of the OECD Model (2012) is to be interpreted as regards interruptions in building site permanent establishments. The history of paragraph 19 of the Commentary on Article 5 (2012) is helpful in that exercise. The author concludes that article 5(3) is to be interpreted under the limited inclusion theory
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 67 (2013), no. 7 ; p. 331-343
http://library.link/vocab/creatorName
Pijl, H
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • OECD Model
  • PE
  • construction project
  • case law
Label
Interruptions in building site permanent establishments to be interpreted under the limited inclusion theory
Instantiates
Publication
Label
Interruptions in building site permanent establishments to be interpreted under the limited inclusion theory
Publication

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