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.
Source and more info: PwC's Tax Policy Bulletin

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