Miscellaneous 2009

The new draft of Article 7 (Business Profits) - first thoughts

Source: The Tax Specialist Journal Article

Published Date: 1 Jun 2009

This article considers the key aspects of the draft Article 7 and commentary focusing on the issue of eliminating double taxation and the introduction of the concept of free capital. The OECD’s stated objectives are to provide greater certainty and clarity in the interpretation of Article 7 and whilst the objectives have not fully been met, this “first draft” has been received with optimism. It will be interesting to see whether the OECD will pull back on its use of broad concepts in its updated draft or whether the pendulum will swing towards more prescriptive drafting in light of submissions received from the OECD community.

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Miscellaneous 2009

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