The Resource Interpretation and application of article 5 (permanent establishment) of the OECD Model tax convention : public discussion draft : 12 October 2011 to 10 February 2012

Interpretation and application of article 5 (permanent establishment) of the OECD Model tax convention : public discussion draft : 12 October 2011 to 10 February 2012

Label
Interpretation and application of article 5 (permanent establishment) of the OECD Model tax convention : public discussion draft : 12 October 2011 to 10 February 2012
Title
Interpretation and application of article 5 (permanent establishment) of the OECD Model tax convention : public discussion draft : 12 October 2011 to 10 February 2012
Creator
Subject
Language
eng
Summary
Article 5 (Permanent Establishment) of the OECD Model Tax Convention includes the definition of the treaty concept of permanent establishment, which is primarily used for the purpose of the allocation of taxing rights when an enterprise of one State derives business profits from another State. Despite the long history of the concept of permanent establishment, its practical application raises a number of issues. The Committee on Fiscal Affairs, through a subgroup of its Working Party 1 on Tax Conventions and Related Questions, has examined various questions related to the interpretation and application of the definition of permanent establishment. This public discussion draft includes proposals for additions and changes to the Commentary on the OECD Model Tax Convention resulting from the work of that subgroup that have recently been presented to the Working Party for discussion. Given the practical importance of these proposals, the Committee has decided to invite public comments on the proposed changes to the Commentary before they are thoroughly discussed by the Working Party. The proposed changes appear in the order of the paragraphs of the current Commentary on Article 5 to which they relate. The Annex includes a consolidated version of paragraphs 1 to 35 of the Commentary on Article 5 that includes all the proposed changes
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
http://bibfra.me/vocab/lite/organizationName
OECD Centre for Tax Policy and Administration
http://library.link/vocab/subjectName
  • OECD
  • OECD Model
  • PE
Label
Interpretation and application of article 5 (permanent establishment) of the OECD Model tax convention : public discussion draft : 12 October 2011 to 10 February 2012
Instantiates
Publication
Extent
59 p.
Label
Interpretation and application of article 5 (permanent establishment) of the OECD Model tax convention : public discussion draft : 12 October 2011 to 10 February 2012
Publication
Extent
59 p.

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