Issues in International Taxation, 7 [electronic resource] : Issues Related to Article 14 of the OECD Model Tax Convention
Publishing, OECD.
Organisation for Economic Co-operation and Development StaffCorporate Author
Paris : Organisation for Economic Co-operation and Development,
2000.
The taxation of professional services and other activities of an independent character under Article 14 of the OECD Model Tax Convention is problematic. For example, what activities and entities fall within Article 14 as opposed to the business profits Article (Article 7)? Is the distinction between those activities and entities satisfactory and easy to apply? What are the practical differences between taxation under Article 7 and 14?. This report analyses those questions in detail and concludes that there is no practical difference between the two Articles or if any differences did in fact ex
Description based upon print version of record.
CONTENTS; Introduction; I. The elimination of Article 14; II. Which activities fall within Article 14?; III. Which entities fall within Article 14?; IV. What are the practical differences concerning taxationunder Articles 7 and 14?; a) Are there differences between the conceptsof "permanent establishment" and "fixed base"?; b) Does Article 14 restrict source taxation to incomefrom services performed personally by the taxpayer?; c) Are the specific rules of paragraphs 2-7 of Article 7 rulesapplicable to Article 14?
d) Are there differences in the source taxation rights grantedunder Articles 7 and 14?e) Does the distinction between Articles 7 and 14 have any impact on domestic law distinctions?; V. Does the elimination of Article 14 require changes to Article 7?; ANNEX: CHANGES TO THE MODEL TAX CONVENTION; Changes to the Articles; Changes to the Commentary
The taxation of professional services and other activities of an independent character under Article 14 of the OECD Model Tax Convention is problematic. For example, what activities and entities fall within Article 14 as opposed to the business profits Article (Article 7)? Is the distinction between those activities and entities satisfactory and easy to apply? What are the practical differences between taxation under Article 7 and 14?. This report analyses those questions in detail and concludes that there is no practical difference between the two Articles or if any differences did in fact ex
Professions -- Taxation -- Law and legislation.
Professions -- Taxation.
Taxation -- Law and legislation.
Issues in international taxation