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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
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 Click here to expand/collapse more articles by Mark L BRABAZON.
 
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