Short-term employment assignments under Article 15(2) of the OECD Model

Abstract

This article summarizes the proceedings of the joint IFA/OECD Seminar at the 2008 IFA Congress in Brussels which examined the tax treatment of short-term assignments of employees under Art. 15 of the OECD Model. The article first reviews the treaty issues raised by the short-term cross-border movement of employees and describes the discussion draft issued by the OECD in 2007 in an effort to clarify the scope of the exception for short-term employment in Art. 15(2). The article then discusses the seven case studies considered by the panel.