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INTERPRETATION AND APPLICATION OF ARTICLE 5 …

www.oecd.org

6 INTERPRETATION AND APPLICATION OF ARTICLE 5 (PERMANENT ESTABLISHMENT) OF THE OECD MODEL TAX CONVENTION INTRODUCTION 1. This note includes the recommendations on the interpretation and application of Article 5

  Notes, Applications, Code, Interpretation, Article, Interpretation and application of article

INTERPRETATION AND APPLICATION OF ARTICLE 5 ... - …

www.oecd.org

Commentary on Article 5 of the OECD Model Tax Convention as it read after 22 July 2010). 1. Can a farm be a permanent establishment? (proposed paragraph 3.1 of the Commentary) Description of the issue 5. Does the fact that income from agriculture is covered by Article 6 prevent a farm from being a permanent establishment? 6.

  Applications, Code, Model, Income, Interpretation, Article, Convention, Oecd model tax convention, Interpretation and application of article

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