Rent-a-star : the purpose of Article 17(2) of the OECD Model

Journal
Bulletin for International Taxation 2002 (Volume 56), No. 10
Examination of the "limited" and "unlimited" approaches of Art. 17(2) of the OECD Model. The main question addressed is: what is fair and necessary regarding Art. 17(2) - the limited approach of the 1977 Commentary or the unlimited taxing right of the 1987 OECD Report and the 1992 Commentary?