MODEL CONVENTION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL 关于所得和财产的税收协定范本 TITLE OF THE CONVENTION 协定标题 Convention between (State A) and (State B) for the elimination of double taxation with respect to taxes on income and on capital and the prevention of tax evasion and...
General Definition of PE: A. Paragraph 1 A fixed place of business, through which the business of an enterprise is wholly or partly carried on. 1) A place of business: a facility such as premises, m…
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...
Principal Purpose TaxCommercial ReasonsEconomic RealityInternational Taxation has a new GAAR: the "Principal Purpose Test" as laid down in Art.29(9) OECD Model Tax Convention (2017) and Art.7 Multilateral InstrumentSocial Science Electronic Publishing...
[Deleted] Art. 15 Income from employment Art. 16 Directors fees Art. 17 Artistes and sportsmen Art. 18 Pensions Art. 19 Government Service Art. 20 Students Art. 21 Other income OECD 3 OECD MODEL TAX CONVENTION CHAPTER IV Taxation of capital Art. 22 Capital CHAPTER V Methods for ...
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 ...
to Ultra, Nova and ST Max 395/495/595 model sprayers only. graco.com 以下有关电 刷的信息和说明仅适用于 Ultra、Nova 和ST Max 395/495/595 型喷涂机。 graco.com It is likely that the future effective tax rate will increase relative to the past, however, as noted above, this w...
Tax TreatiesTreaty InterpretationHistory of the OECD Model Tax Convention on Income and CapitalThe article reviews the history of article 1 ('Persons Covered') of the OECD Model Tax Convention as a basis to analyse the provision's role and function in relJohann Hattingh...
Development(OECD)Model Tax Convention on Income and Capital2(hereinafter referred to as the OECD Model Convention), [...] daccess-ods.un.org daccess-ods.un.org 目的是通过简要强 调每一条款的范围提供其非正式摘要,同时注意《联合国示范公约》最新(2011 ...
and considers the current standards in the OECD and the UN model tax conventions, and the new Multilateral Convention. The toolkit discusses economic considerations that may guide policy in this area, the types of assets that could appropriately attract tax when transferred indirectly offshore, implem...