A Construction Consortium as a Permanent Establishment from an International Tax Law Perspective: Inconsistencies and Deficiencies in Article 5(3) of the OECD Model and Commentary

Journal
International
Bulletin for International Taxation 2012 (Volume 66), No. 1
In this article, the author considers key difficulties in the interpretation and application of article 5(3), in conjunction with article 7, of the OECD Model regarding the taxation of a non-resident investor forming a joint-venture with a resident enterprise to undertake a substantial construction or infrastructure project in the latter’s residence state.