Transcription of INTERPRETATION AND APPLICATION OF ARTICLE …
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INTERPRETATION AND APPLICATION OF ARTICLE …
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT INTERPRETATION AND APPLICATION OF ARTICLE 5 ( permanent establishment ) OF THE OECD MODEL TAX CONVENTION 12 October 2011 to 10 February 2012 CENTRE FOR TAX POLICY AND ADMINISTRATION 2 12 October 2011 INTERPRETATION AND APPLICATION OF ARTICLE 5 ( permanent establishment ) OF THE OECD MODEL TAX CONVENTION Public discussion draft 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.
2 12 October 2011 INTERPRETATION AND APPLICATION OF ARTICLE 5 (PERMANENT ESTABLISHMENT) OF THE OECD …
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