Published on 01 Jun 09
by "THE TAX SPECIALIST" JOURNAL ARTICLE
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.
Neil is a Principal of Corporate and International Tax with Deloitte Touche Tohmatsu Ltd.
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01 June 2010