INTERPRETATION AND APPLICATION OF ARTICLE 5 ... - …

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. Despite the long history of the concept of permanent establishment, its practical APPLICATION raises a number of issues. The Committee on Fiscal Affairs, through a subgroup of its Working Party 1 on Tax Conventions and Related Questions, has examined various questions related to the INTERPRETATION and APPLICATION of the definition of permanent establishment.

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.

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

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