OECD iLibrary Issues Related to Article 14 of the OECD oecd model article 14 Model Tax Convention
OECD iLibrary Issues Related to Article 14 of the OECD oecd model article 14 Model Tax Convention
This series of publications examines various issues in international taxation. Most of the reports relate to the OECD Model Tax Convention on Income and on Capital. OECD iLibrary Issues Related to Article 14 of the OECD oecd model article 14 Model Tax Convention
OECD iLibrary Issues Related to Article 14 of the OECD oecd model article 14 Model Tax Convention
OECD iLibrary is the online library of the Organisation for Economic Cooperation and Development featuring its books, papers and statistics and is the knowledge base of OECD's analysis and data. Issues Related to Article 14 of the OECD Model Tax Convention 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, oecd model article 14 what activities and entities fall within Article 14 as opposed to the business profits Article ? 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 exist, there is no valid policy justification for them. It recommends that Article 14 be eliminated from the Model and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence. cic limited by guarantee model articles