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The Attribution of Profits and Capital Structure to a Permanent Establishment under the OECD Model Tax Treaty

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.

Author profile

Mark Brabazon CTA
Dr Mark Brabazon SC advises and represents corporate, private and government clients in cases involving income tax, GST and State taxes, acting at all levels from planning and advice through audit, investigation and ADR to final appeal. He is the author of International Taxation of Trust Income: Principles, Planning and Design (CUP, 2019), the GTTC chapter on ‘Application of Tax Treaties to Fiscally Transparent Entities’, and many other publications on Australian and international tax. He is a member of 7 Wentworth Selborne. - Current at 15 May 2020
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