Published on 01 Apr 10
by "THE TAX SPECIALIST" JOURNAL ARTICLE
The OECD released a revised draft of Article 7 and its commentary in November 2009 based on consultation with professional bodies and representatives from the business community. The most important change in this second draft is the replacement of the paragraph dealing with double taxation in relation to free capital with a much broader provision, although the concept of free capital itself remains. A key measure will be effective implementation of these provisions by Competent Authorities.
Neil is a Principal of Corporate and International Tax with Deloitte Touche Tohmatsu Ltd.
- Current at
26 October 2012