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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Bibliographic Details
Corporate Author: Organisation for Economic Co-operation and Development
Format: eBook
Language:English
Published: Paris OECD Publishing 2000
Series:Issues in International Taxation
Subjects:
Online Access:
Collection: OECD Books and Papers - Collection details see MPG.ReNa
Description
Summary: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
Physical Description:48 p. 16 x 23cm
ISBN:9789264181236