The Construction Clause in Article 5(3) of the OECD Model

Journal
Seitz, G.
Germany; OECD
Bulletin for International Taxation 2013 (Volume 67), No. 9
PriceUSD 45

This article examines issues arising from the interpretation and application of the construction clause in article 5(3) of the OECD Model (2010). It evaluates the recent case law from various countries as well as the comments on the permanent establishment definition in the Revised Discussion Draft on Article 5 of the OECD Model (2010).