By OECD. Published by : OECD Publishing
This booklet is the 6th variation of the Condensed model of the OECD version Tax conference on source of revenue and Capital. This shorter model comprises the whole textual content of the Articles, statement, and nation Positions of the version Tax Conve
Read or Download Model Tax Convention on Income and on Capital Model Tax Convention on Income and on Capital: Condensed version -- July 2005 PDF
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This book is the 6th version of the Condensed model of the OECD version Tax conference on source of revenue and Capital. This shorter model comprises the complete textual content of the Articles, statement, and nation Positions of the version Tax Conve
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Additional info for Model Tax Convention on Income and on Capital Model Tax Convention on Income and on Capital: Condensed version -- July 2005
5. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the interest, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment in connection with which the indebtedness on which the interest is paid was incurred, and such interest is borne by such permanent establishment, then such interest shall be deemed to arise in the State in which the permanent establishment is situated.
Where the application of the Convention is so refused, the partners should be entitled, with respect to their share of the income of the partnership, to the benefits provided by the Conventions entered into by the States of which they are residents to the extent that the partnership’s income is allocated to them for the purposes of taxation in their State of residence (cf. 4 of the Commentary on Article 4). 6. The relationship between the partnership’s entitlement to the benefits of a tax Convention and that of the partners raises other questions.
By having a place of management) in that state to which all or a substantial part of its profits were properly attributable. 11. A further example is provided by two particularly prevalent forms of improper use of the Convention which are discussed in two reports from the Committee on Fiscal Affairs entitled "Double Taxation Conventions and the Use of Base Companies" and 1 "Double Taxation Conventions and the Use of Conduit Companies". As indicated in these reports, the concern expressed in paragraph 9 above has proved to be valid as there has been a growing tendency toward the use of conduit companies to obtain treaty benefits not intended by the Contracting States in their bilateral negotiations.