2. As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires or the competent authorities agree to a different meaning pursuant to the provisions of Article 25, have the meaning that it has at th...
1. the location should be considered to be at the disposal of an enterprise, which means the enterprise has the effective power to use that location as well as the extent of the presence of the enterprise at that location and the activities that it performs there. – exemption: if thebusin...
OECD approves the 2017 update to the OECD Model Tax Convention 23/11/2017 - On 21 November 2017, the OECD Council approved thecontents of the 2017 Updateto theOECD Model Tax Convention(the OECD Model). The 2017 Update, which was previously approved by the Committee on Fiscal Affairs on 28...
doi:10.2139/ssrn.3794565The paper forms part of the book compiling papers presented at the MaiSymposium at WU in 2020. The paper discusses the meaning and scope of various terms in ArtSocial Science Electronic Publishing
oecd税收协定范本2017中文版合集 OECD税收协定范本(中英对照文本 MODEL CONVENTION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL 经济合作与发展组织关于 对所得和财产征税的协定范本 TITLE AND PREAMBLE CHAPTER I Scope of the Convention 标题和序言 第一章 协定范围 Art. 1 Persons Covered Art. 2 Taxes ...
OECD范本.pdf,ARTICLES OF THE MODEL CONVENTION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL [as they read on 28 January 2003] SUMMARY OF THE CONVENTION TITLE AND PREAMBLE CHAPTER I Scope of the Convention Art. 1 Persons Covered Art. 2 Taxes covered CHAP
目前唯一能够适用于增值税领域的多边公约是《多边税收征管互助公约》(The Multilateral Convention on Mutual Administrative in Tax Matters)。《多边税收征管互助公约》主要包含信息交换、税款征收协助和文书送达三种征管互助方式。但是《多边...
The guidelines provide guidance on the application of the "arm's-length principle" set forth in Article 9 (associated enterprises) of the OECD Model Tax Convention. Thus, the same interpretive principles that guide treaty interpretation also play an important role with respect...
RP 一般指具有参与执 行 CRS 的税收辖区居民身份的自然 人(包括留有遗产的死者)和实体 ; 对于合伙、有限合伙或其他没有纳税① /n2226/n2271/n2274/index.html/n2226/n2271/n2274/index.html,2014-7-8.② /ctp/exchange-of-tax-information/Status_of_convention.pdf/ctp/exchange-of-tax-information/...
The GTA has at all times maintained that its claim should be determined in Germany by the German tax courts, per the UK-Germany double taxation Treaty, based on the OECD model convention (for those in the know: it is Article 28(6) which the GTA has suggested exclusively reserves its GTA...