Origins of concepts and expressions used in the OECD Model and their adoption by States.
01 Nov 06 |
BRITISH TAX REVIEW
Issue: Number 6 2006
This article traces the derivation of the terms used in the OECD Model to their original state or states, and the converse, the extent to which the model has influenced states' internal law. There is virtually no concept in any of the models that cannot be found in an earlier treaty. The models have in turn influenced later treaties. The origins of expressions, and of the treaty categories of income, have mostly been traced to internal law and treaties of mainland European countries which led treaty practice after the First World War. The influence of common law is far more limited. The models have to a much smaller extent influenced international law, the permanent establishment concept being the main exception.
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Richard is Challis Professor of Law at the University of Sydney and has taught at Harvard and NYU Law Schools and the Universities of Amsterdam, London and Oxford. Richard has worked in the past at the IMF and OECD and held many Government consultancies in Australia and elsewhere. He has been a consultant for specialist tax firm Greenwoods & Herbert Smith Freehills since 1985. Richard specialises in corporate and international taxation on which he has published widely both in Australia and internationally.
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11 July 2019