Attribution of Profits to Permanent Establishments: The 2008 Article 7 versus the 2010 Article 7 of the OECD Model Tax Convention

Abstract

This article compares the 2008 article 7 with the 2010 article 7 of the OECD Model Tax Convention, illustrates the similarities and differences using a case study and briefly deals with the implementation of the 2010 article 7 in the double tax treaty network of Switzerland, Germany and Austria.