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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