Discussion Draft on a New Art. 7 of the OECD Model Convention

Journal
International Transfer Pricing Journal 2009 (Volume 16), No. 2
This article provides an overview of the discussion draft on a new Art. 7 of the OECD Model Tax Convention (OECD Model), which was released in July 2008. It describes the background to the discussion draft, the new Art. 7 and its Commentary, and the proposed consequential changes to other parts of the OECD Model. It is expected that, once finalized, the proposed changes will be included in the next update of the OECD Model.