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...
| Autor principal: | |
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| Autor Corporativo: | |
| Formato: | Libro electrónico |
| Idioma: | Inglés |
| Publicado: |
Paris :
OECD Publishing
2000.
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| Colección: | Issues in International Taxation,
no.7. |
| Materias: | |
| Ver en Biblioteca Universitat Ramon Llull: | https://discovery.url.edu/permalink/34CSUC_URL/1im36ta/alma991009706000906719 |
Tabla de Contenidos:
- Intro
- CONTENTS
- Introduction
- I. The elimination of Article 14
- II. Which activities fall within Article 14?
- III. Which entities fall within Article 14?
- IV. What are the practical differences concerning taxation under Articles 7 and 14?
- a) Are there differences between the concepts of "permanent establishment" and "fixed base"?
- b) Does Article 14 restrict source taxation to income from services performed personally by the taxpayer?
- c) Are the specific rules of paragraphs 2-7 of Article 7 rules applicable to Article 14?
- d) Are there differences in the source taxation rights granted under Articles 7 and 14?
- e) Does the distinction between Articles 7 and 14 have any impact on domestic law distinctions?
- V. Does the elimination of Article 14 require changes to Article 7?
- ANNEX: CHANGES TO THE MODEL TAX CONVENTION
- Changes to the Articles
- Changes to the Commentary.
