What people are saying - Write a review
We haven't found any reviews in the usual places.
WORK OF THE GROUP OF EXPERTS ON TAX TREATIES 25 51+
Part two Guidelines for tax treaties between developed
TAXATION OF BUSINESS PROFITS
5 other sections not shown
activities administrative agreed agreement allocation amount apply approach appropriate arm's length principle bilateral negotiations bilateral treaties business profits capital capital-exporting countries concept of permanent considered Contracting Convention of l963 country of residence country of source deductions dependent agent determination developed and developing developing countries felt discussion domestic double taxation Draft Model Convention exchange of information exemption expenditures expenses Fiscal Committee fixed base foreign tax gross royalty Group of Experts head office home country income interest and royalties investment investor involved limitation members from developing merchandise method OECD Draft Convention OECD Draft Model OECD Model Convention paragraph patent place of effective provisions purchase rate of tax recipient residence country revenue royalty payments shipping enterprise shipping profits situated source country subsidiary Summary of consideration tax evasion tax rate tax treaties taxable taxation at source Text of OECD transfer pricing treaties between developed unilateral withholding rates withholding tax