Tax treaty law and Community law : some recent developments

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Summary: This article deals with general development in tax treaty law and the impact that these developments have on Community law. The following topics are examined: proposed changes to the commentary on Article 5 of the OECD Model to include the concept of a service PE; proposed changes to the commentary on Article 17 of the OECD Model to include the net basis of taxation of non-resident artistes and sportsmen; adoption of the 'functionally separate entity' approach for the calculation of profits of a PE pursuant to Article 7 of the OECD Model; and, proposed changes to the Mutual Assistance Procedure of Article 25 of the OECD Model to supplement the current procedure with arbitration

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Summary: This article deals with general development in tax treaty law and the impact that these developments have on Community law. The following topics are examined: proposed changes to the commentary on Article 5 of the OECD Model to include the concept of a service PE; proposed changes to the commentary on Article 17 of the OECD Model to include the net basis of taxation of non-resident artistes and sportsmen; adoption of the 'functionally separate entity' approach for the calculation of profits of a PE pursuant to Article 7 of the OECD Model; and, proposed changes to the Mutual Assistance Procedure of Article 25 of the OECD Model to supplement the current procedure with arbitration