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The revised draft of Article 7 Business Profits – on second thoughts…

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.

Author profile:

Neil Pereira CTA
Neil is a Principal of Corporate and International Tax with Deloitte Touche Tohmatsu Ltd. Current at 01 June 2010 Click here to expand/collapse more articles by Neil PEREIRA.
 
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