IFA: The OECD Model Convention - 1996 and Beyond
The OECD Model Convention--1996 and Beyond offers accounts of the papers delivered and the discussions held in the context of this popular seminar at IFA's Congress of Geneva in September 1996. The seminar comprised two components:
Practitioners and academics whose work involves or is affected by the OECD Model Convention will appreciate this insightful publication.
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- Introductory Notes
Works of the OECD I; J. Owens
Works of the OECD II; D. Lütti
Allocation of Profits under Article 14
To Which Extent do Employees Assigned to a Subsidiary Constitute a Permanent Establishment of the Parent Company?
Appendix 1: The OECD Committee on Fiscal Affairs
Appendix 2: Outline on Article 14
Appendix 3: Outline on Employees as a Permanent Establishment
Appendix 4: The Origins of OECD Model Articles 7, 14 and 15