BLOG ABOUT TRANSFER PRICING, INTERNATIONAL TAXATION AND SPANISH TAXES (by Antonio Pina)
martes, 25 de octubre de 2011
OECD discussion draft on Article 5 (Permanent Establishment) of the OECD Model Tax Convention
The OECD has recently published a public discussion draft entitledInterpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention. The discussion draft proposes a number of changes affecting the application of the treaty rules which deal with the circumstances in which a taxable presence or ‘permanent establishment’ may be created.