Interruptions in Building Site Permanent Establishments To Be Interpreted under the Limited Inclusion Theory

Journal
Pijl, H.
International; OECD
Bulletin for International Taxation 2013 (Volume 67), No. 7
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In this article, the author examines how article 5(3) of the OECD Model (2012) is to be interpreted as regards interruptions in building site permanent establishments. The history of paragraph 19 of the Commentary on Article 5 (2012) is helpful in that exercise. The author concludes that article 5(3) is to be interpreted under the limited inclusion theory.