Source and more info: pwc
jueves, 15 de noviembre de 2012
Revised Proposals on Article 5 (Permanent Establishment) of the OECD Model Tax Convention
The OECD has recently published its revised proposals on Permanent Establishments in a paper entitled “OECD Model Tax Convention: Revised Proposals concerning the Interpretation and Application of Article 5 (Permanent Establishment)”. The document 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.