The OECD's attempts to gain international consensus on applying a tax convention for enterprises carrying on business in another country appears to be having a mixed result.
The commentary to Article 7 of the OECD Model Tax Convention did not provide any detailed instructions on how this should be carried out and OECD member states have adopted a variety of practices.
In this article, first published in Taxation Today in June 2009, Bell Gully senior solicitor Campbell Pentney looks at the OECD's attempts to standardise Article 7's application, including a recent shift in interpretation away from the approach preferred by New Zealand Inland Revenue.
Click here to read the article, The attribution of profits to permanent establishments: recent OECD developments.
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