Published on 01 Jul 03
by "AUSTRALIAN TAX FORUM" JOURNAL ARTICLE
This paper considers the attribution of profits to a permanent establishment under Article 7 of the OECD Model Tax Convention on Income and on Capital (Model Treaty)
1 with particular reference to the recognition of internal dealings, profits and capital structure of the taxable entity and its branches.
Mark is a Barrister specialising in equity, revenue and constitutional law. He appears regularly in revenue cases and is an external member of the Australian Taxation Office's Litigation Panel. Previously he practised as a Solicitor and Lecturer in law and was engaged in research at the High Court.
- Current at
01 July 2003