Abstract
This article presents an overview of the implications of the conclusions of the OECD Report on the Attribution of Profits to Permanent Establishments with regard to internal interest dealings for both financial enterprises (for the interpretation of existing treaties based on the current text of Art. 7 of the OECD Model) and non-financial enterprises (for the interpretation of future tax treaties or future amendments to existing treaties based on the text of the Draft new Art. 7).
Talk to us
Join us for a 30 min session where you can share your feedback and ask us any queries you have
Disclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.