Interpretation of Article 7 of the OECD Model, Permanent Establishment Financing and Other Dealings

Journal
Pijl, H.
International; Netherlands; OECD
Bulletin for International Taxation 2011 (Volume 65), No. 6
PriceUSD 45

This article considers the principles and issues involved in the interpretation of article 7 of the OECD Income and Capital Model (2008), particularly regarding capital and interest attribution, other dealings, the influence of the non-discrimination article on capital attribution, and the practical question of from when the new OECD rules have effect.