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Tuesday, August 4, 2020 | History

2 edition of Issues related to Article 14 of the OECD model tax convention found in the catalog.

Issues related to Article 14 of the OECD model tax convention

Issues related to Article 14 of the OECD model tax convention

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  • 8 Currently reading

Published by Organisation for Economic Co-operation and Development in Paris .
Written in English

    Subjects:
  • Partnership -- Taxation

  • Edition Notes

    SeriesIssues in international taxation -- no. 7
    The Physical Object
    Pagination45 p. ;
    Number of Pages45
    ID Numbers
    Open LibraryOL16999516M
    ISBN 109264176438

    Issues Related to Article 14 of the OECD Model Tax Convention OECD This book recommends that Article 14 be eliminated from the OECD Model Tax Convention and describes the changes that would need to be made to the Articles and Commentary of the Model as a ://   If Nigeria uses a deduction at source model, it is unlikely to capture enough of the tax base to warrant the trouble, since most transactions contemplated are ://

      This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July , including the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back The Application of the OECD Model Tax Convention to Partnerships -- R Issues Related to Article 14 of the Model Tax Convention -- R Restricting the Entitlement to Treaty Benefits -- R Treaty Characterisation Issues Arising from E-Commerce -- R Issues Arising under Article 5 (Permanent Establishment) of the Model Tax Convention -- R

    The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring ://   OECD Model Tax Convention on Income and on Capital. This paper served as a basis for the discussions during the conference. As many contributors refer to this paper and in particular to the research questions contained therein, it has been reprinted in this book as a general introduction to the ://


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Issues related to Article 14 of the OECD model tax convention Download PDF EPUB FB2

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 :// This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital.

This full version contains the full text of the Model Tax Convention as it read on 21 Novemberincluding the Articles, Commentaries, non-member economies’ positions, the Recommendation of the OECD Council, the historical notes and the background   ISSUES RELATED TO ARTICLE 17 OF THE OECD MODEL TAX CONVENTION INTRODUCTION 1.

Under Article 17 of the OECD Model Tax Convention, the State in which the activities of a non-resident entertainer or are performed is allowed to tax the income derived from these sportsperson   Data and research on tax treaties including OECD Model Tax Convention, Mutual Agreement Procedure Statistics, prevention of treaty abuse., The taxation of professional services and other activities of an independent character under Art.

14 of the OECD Model Tax Convention is problematic. This report studies this problem, the update Model includes the Data and research on tax treaties including OECD Model Tax Convention, Mutual Agreement Procedure Statistics, prevention of treaty abuse., This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital.

This shorter version contains the articles and commentaries of the Model Tax Convention on Income and Capital as it read on 21 November   OF THE OECD MODEL TAX CONVENTION INTRODUCTION 1. This note includes the recommendations on the interpretation and application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention made by a Working Group composed of delegates to Working Party 1 on Tax Conventions and Related Questions of the OECD Committee on This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 Julyincluding the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back to This book recommends that Article 14 be eliminated from the OECD Model Tax Convention and describes the changes that would need to be made to the Articles and Commentary of the Model as a 「Issues related to article 14 of the OECD model tax convention」を図書館から検索。カーリルは複数の図書館からまとめて蔵書検索ができるサービスです。   : Issues in International Taxation No.

Issues Related to Article 14 of the OECD Model Tax Convention (): OECD. Published by: OECD Publishing:  › Books › Business & Money › Taxation. This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on full version contains the full text of the Model Tax Convention as it read on 21 Novemberincluding the Articles, Commentaries, non-member economies’ positions, the Recommendation of the OECD Council, the historical notes and the background ://   treaty-related international tax cooperation issues.

In the s, the Ad Hoc Group of Experts recognized that with the OECD Model Convention. In drawing upon the United Nations Model Get this from a library. Issues Related to Article 14 of the OECD Model Tax Convention.

[Organisation for Economic Co-operation and Development.] -- 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 Get this from a library. Issues related to Article 14 of the OECD model tax convention. [Organisation for Economic Co-operation and Development.;] -- 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 The OECD Model Tax Convention helps resolve such problems, though it is not binding by law. Rather, the OECD issues a Recommendation based on the common position of its members, who in turn commit to follow the model and its commentaries, while taking on board its reservations, when concluding or revising bilateral tax ://   • Tax treaties concluded between South Africa and other jurisdictions generally contain Article 25 on MAP based on the Convention.2 The Convention is an OECD model tax treaty, which has been developed by the OECD.

Article 25 of the Convention provides that the competent authorities shall endeavour, by mutual agreement, to resolve the - Guide on Mutual Agreement.

Get this from a library. Issues related to Article 14 of the OECD model tax convention. [Organisation for Economic Co-operation and Development.;] -- This report deals with a number of problems relating to the interpretation and application of Article It recommends the elimination of that Article 14 from the Model Tax Convention and identifies   OECD updates Model Tax Convention action 14 (Making Dispute Resolution More Effective).

Of particular note to transfer pricing practitioners are changes The rules in Article related to arbitration have also been modified, and the commentaries to Article 25 Get this from a library.

Issues Related to Article 14 of the OECD Model Tax Convention. [Organisation for Economic Co-operation and Development.;] This publication is the eighth edition of the full version of the OECD Model Tax Convention on Income and on full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 22 Julyincluding the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back.

Hybrid Entities in Tax Treaty Law: Issues, their Source and Possible Solutions 4 Govind/Van West (Eds), Hybrid Entities in Tax Treaty Law, Linde 1. Introduction On 5 Octoberthe OECD published the Final Report on Neutralising the Effects of Hybrid Mismatch Arrangements.1, which is an output of the Action 22 of the BEPS Final Report contains recommendations to counter issues  OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations July OECD Transfer Pricing Guidelines for Multinational Enterprises and  E/C//CRP.8 Page 2 of 56 Article 5 PERMANENT ESTABLISHMENT A.

GENERAL CONSIDERATIONS 1. Article 5 of the United Nations Model Convention is based on Article 5 of the OECD Model