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.
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