These comments will be examined at the next meeting of the Working Party. Geographical Scope of Article 13(1) 202 3.1 Bilateral Reach 202 3.2 Versions in 1963 OECD Model and 1977-2005 OECD Models 203 4. %����
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Chapter 3: The Work of the OEEC/OECD on Tax Matters 77 3.1. OECD vs. UN Model Income Tax Convention •Models are mostly identical •But with significant exceptions: –Historically UN Model more source state taxation rights (e.g., services PE, force of attraction, royalty withholding, capital gains real property companies) –UN has not followed OECD’s new Article 7 –UN has not dropped Article 14. This resulted in the publication in 1977 of a new Model Convention. that the Model Convention continues to reflect accurately the views of member countries at any point in time. These recommendations result from consultation with member countries, following the 1963 Draft Convention. Publication date 1987 Related Work OECD model income tax treaties and commentaries. from application/x-indesign to application/pdf xmp.id:1F8CDCEB254FE6118022811461A24B97 endobj
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}�����G�������t�� ������:�$��$�d���-HWt��k:��{* ���uA'Bd7T�lZRa�@�q��|���r�/�w��%�:��N1�i���-�d`f�s}̂�kjP+u���UQ�}N���t�6?��6{-���*��ܝ���8Q��� �]��bt�L#��X@?� g/ȷ7���(q:���>g���:���0���fZ�j�h�4A/�T�X��rv�jhr X��� Adobe InDesign CS6 (Windows) OECD Model and Other Model Conventions 197 1.1 OECD Model 197 1.2 Other Model Conventions 198 2. Taxation of services in the 1963 OECD Draft 82 3.1.1.1. This resulted in the publication in 1977 of a new Model Convention. Permanent establishment concept 82 3.1.1.2. The 1977 OECD Model Double Taxation Convention on Income and on Capital 68 4.2.5. This Convention shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 3 of Article 7, paragraph 2 of Article 9 and Articles 19, 20, 23 [A] [B], 24, 25 and 28. Taxation of services in the 1977 OECD Model Convention 91 3.2.1.1. 1977 OECD Model Convention 90 3.2.1. Independent personal services 89 3.2. / 9789065443304 (pbk.) OECD Model Tax Convention for possible inclusion through the next update, which is currently scheduled for 2014. 2016-07-21T11:35:39+02:00 that the Model Convention continues to reflect accurately the views of member countries at any point in time. Double taxation is the taxation of a single taxpayer with respect to the same subject matter over the same period in more than one country. <>>>
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It therefore invites interested parties to send their comments on this discussion draft before 10 February 2012. stream
partnerships and associations as nationals of a Contracting State is taken from the OECD Model Draft Income Tax Convention of January, 1977, where it appears in Article 24 (Non-Discrimination). 2016-07-21T11:35:39+02:00 This 1977 report contains the recommendations of the Committee on Fiscal Affairs for the avoidance of double taxation on income and capital. Adobe PDF Library 10.0.1 2 0 obj
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$.' Since then, the pressure to update and adapt the OECD Model to changing economic conditions has progressively increased. The guidelines provided by the OECD in the interpretation of article 17 73 4.2.6. x��YKo�8���Q,`��! uuid:b3db9a6a-2045-4bb3-a7a0-74778b8d1264 %PDF-1.4
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