Part 1. Restricting the entitlement to treaty benefits -- Part II. Treaty characterisation issues arising from e-commerce -- Part III. Issues arising under Article 5 (permanent establishment) of the Model Tax Convention
Summary
This publication includes three recent reports of the Committee on Fiscal Affairs that resulted in changes to the OECD Model Tax Convention on Income and Capital. The first considers how to address situations where it would seem inappropriate to grant the benefits of tax treaties. The second examines the characterization of various types of electronic commerce payments under tax conventions. The third provides background for changes made to the Commentary on Article 5