Search results with tag "Model tax convention"
COMMENTARIES ON THE ARTICLES OF THE MODEL TAX …
www.oecd.orgApplication of the OECD Model Tax Convention to Partnerships”, 1 the conclusions of which have been incorporated below and in the Commentary on various other provisions of the Model Tax Convention. 3. As discussed in that report, a main source of difficulties is the fact that some
2017 UPDATE TO THE MODEL TAX CONVENTION - OECD
www.oecd.orgThe 2017 pdate primarily comprises changes to the OECD Model Tax Convention U (the OECD Model) ... and related Commentary changes, concerning the treaty residence of ... discussed at a7 September 2012 public consultation and subsequently released in a revised October 2012discussion draft .
2017 UPDATE TO THE MODEL TAX CONVENTION - OECD
www.oecd.orgThe 2017 pdate primarily comprises changes to the OECD Model Tax Convention U (the OECD Model) that were approved as part of the BEPS Packageor were foreseen as part of the follow -up work on the treaty-related BEPS measures. These changes include the following:
KPMG report: Summary and initial analysis of Pillar Two ...
assets.kpmgdefinition of a recognised pension fund under the OECD Model Tax Convention on Income and Capital 2017 (“OECD Model Tax Convention”). In particular, the definition under the Pillar Two Blueprint does not include the requirement that the pension fund be …
DEPARTMENT OF THE TREASURY THE GOVERNMENT OF …
www.treasury.govNegotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development, as updated in April 2000 (the “OECD Model”), and recent tax treaties concluded ... in the United States and the income from the services is not attributable to a permanent .
Model Tax Convention on Income and on Capital
www.fondazionenazionalecommercialisti.itOECD MODEL TAX CONVENTION 26 OECD Article 4 RESIDENT 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and