Issues Related to Article 14 of the OECD Model Tax Convention

The taxation of professional services and other activities of an independent character under Article 14 of the OECD Model Tax Convention is problematic. For example, what activities and entities fall within Article 14 as opposed to the business profits Article (Article 7)? Is the distinction between...

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Detalles Bibliográficos
Autor principal: Organisation for Economic Co-operation and Development.
Autor Corporativo: Organisation for Economic Co-operation and Development (-)
Formato: Libro electrónico
Idioma:Inglés
Publicado: Paris : OECD Publishing 2000.
Colección:Issues in International Taxation, no.7.
Materias:
Ver en Biblioteca Universitat Ramon Llull:https://discovery.url.edu/permalink/34CSUC_URL/1im36ta/alma991009706000906719
Descripción
Sumario:The taxation of professional services and other activities of an independent character under Article 14 of the OECD Model Tax Convention is problematic. For example, what activities and entities fall within Article 14 as opposed to the business profits Article (Article 7)? Is the distinction between those activities and entities satisfactory and easy to apply? What are the practical differences between taxation under Article 7 and 14? This report analyses those questions in detail and concludes that there is no practical difference between the two Articles or if any differences did in fact exist, there is no valid policy justification for them. It recommends that Article 14 be eliminated from the Model and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence.
Descripción Física:1 online resource (48 pages)
ISBN:9781280029837
9786610029839
9789264181236