Tax treaty law and Community law : some recent developments

Resource Information

The work Tax treaty law and Community law : some recent developments represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Tax treaty law and Community law : some recent developments

Creator

• HJI Panayi, C

Subject

• OECD Model
• PE
• entertainer
• EU tax law
• services PE
• sportsperson
• mutual assistance

Language

eng

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

Citation source

In: The EC tax journal. - Oxford. - Vol. 9 (2007),

Geographic coverage

• European Union
• Europe

Language note

English