Search results with tag "Oecd model tax convention"
ARTICLES OF THE MODEL CONVENTION WITH RESPECT TO …
www.oecd.orgOECD MODEL TAX CONVENTION 6 OECD CHAPTER I SCOPE OF THE CONVENTION Article 1 PERSONS COVERED This Convention shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED 1. This Convention shall apply to taxes on income and on capital imposed on behalf
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:
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
COMMENTARIES ON THE ARTICLES OF THE MODEL TAX …
www.oecd.org2. Domestic laws differ in the treatment of partnerships. These differences create various difficulties when applying tax Conventions in relation to partnerships. These difficulties are analysed in the report by the Committee on Fiscal Affairs entitled “The Application of the OECD Model Tax Convention to Partnerships”, 1 the conclusions of
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 …
ARTICLES OF THE OECD MODEL TAX CONVENTION ON …
www.oecd.orgARTICLES OF THE OECD MODEL TAX CONVENTION ON INCOME AND CAPITAL [as they read on 22 July 2010]
TRANSFER PRICING GUIDELINES
phl.hasil.gov.my140A of the Income Tax Act, 1967 and the Income Tax (Transfer Pricing) Rules 2012. All enquiries may be ... control or capital of the other company; or the ... 6.2 The arm's length principle is stated in paragraph 1 of Article 9 of the OECD Model Tax Convention as: "Where . . . conditions are made or imposed between the two
Statement on a Two-Pillar Solution to Address the Tax ...
www.oecd.orgincome under the OECD Model Tax Convention. Simplifications . To ensure that the administration of the GloBE rules are as targeted as possible and to avoid compliance and administrative costs that are disproportionate to the policy objectives, the implementation framework will include safe harbours and/or other mechanisms. GILTI co-existence
INTERPRETATION AND APPLICATION OF ARTICLE 5 ... - …
www.oecd.orgCommentary 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.
Commentary on: OECD Model tax convention: Revised ...
www.oecd.orgLegal ownership of an asset means that the legal person or individual (“Person”) claiming legal ownership is regarded to be the legal owner under the (civil) laws of the country in
INTERPRETATION AND APPLICATION OF ARTICLE …
www.oecd.orgorganisation for economic co-operation and development interpretation and application of article 5 (permanent establishment) of the oecd model tax convention
OECD MODEL TAX CONVENTION: REVISED …
www.oecd.orgoecd model tax convention: revised proposals concerning the meaning of “beneficial owner” in articles 10, 11 and 12 19 october 2012 to 15 december 2012
OECD MODEL TAX CONVENTION: Tax Treaty Treatment of ...
www.oecd.org2.5 A payment made with respect to unused holidays / sick days that accrued during the last year of employment is part of the remuneration for the period of work that generated the holiday
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