The article contains an overview of the changes in the OECD Model Convention, approved by the OECD Council. As a result of the pressure exercised by the business community, which feared the widespread use of the principles set out by the Italian Supreme Court, the OECD has now amended the ...
OECD Model Tax Convention and Commentary(2010 version) 热度: 2014 Update to the OECD Model Tax Convention:2014更新OECD税收协定范本 热度: The OECD-model-convention and its update 2014 热度: 5 OECDMODELTAXCONVENTIONONINCOMEANDONCAPITAL2010 CHAPTERI–SCOPEOFTHECONVENTION ...
OECD Model Tax Convention and Commentary(2010 version) 热度: SLIDE-OLOGY中文版 热度: 2010年版 OECD双边税收协定范本 热度: REWARDINGJOBS: GovernmentPolicy andWorkIncentives ChristopherHeadyOECD,CentreforTaxPolicyandAdministration HerwigImmervoll OECD,Employment,LabourandSocialAffairs ...
Article 26 of the OECD Model Tax Convention on Income and on Capital and its CommentaryThe competent authorities of the Contracting States shall exchange such information as is foreseeably relevant for carrying out the provisions of this Convention or to the administration or enforcement of the ...
changes to the Title and Preamble of the OECD Model, changes to the section of the Commentary on Article 1 (Persons covered) on “Improper use of the Convention”, and a new Article 29 (Entitlement to Benefits), which includes in the OECD Model a limitation-on-benefits (LOB) rule (simpl...
The July 2023 statement indicates that the STTR is an integral part of the consensus on Pillar Two for developing countries in the Inclusive Framework. Work has been completed on an STTR model provision and commentary for incorporating it into bilateral tax treaties. The STTR will apply to ...
This discussion draft includes the proposed changes to the Commentary on Articles 10, 11 and 12 of the OECD Model Tax Convention that the Working Party has drafted for that purpose. The Committee intends to ask the Working Party to review these proposed changes in light of the comments from ...
The inclusion of the Amount B guidance into the OECD Guidelines is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention and is interdependent of the signing and entry into force of the Multilateral Convention to Implement Amount A...
Dispute resolution mechanisms The mutual agreement procedure (MAP) provision in Article 25 of the OECD Model Tax Convention6 can serve as a basis for developing a separate GloBE dispute resolution mechanism. Such mechanism could be implemented through different legal instruments, such as a new ...
OECD Model Tax Convention and Commentary(2010 version) 热度: 2010年版 OECD双边税收协定范本 热度: OECD养老政策分析及与中国养老评价指数的对比 热度: NewAnalyticalProductsoftheITC IncooperationwithOECD,UNSDandWTO MarketAnalysisSection 6thOECDInternationalTradeStatisticsExpertMeeting(ITS) ...