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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.

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Mark L BRABAZON

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