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Issues Related to Article 14 of the OECD Model Tax Convention (Issues in International Taxation Series No. 7)

Issues Related to Article 14 of the OECD Model Tax Convention    
Format Softcover
Catalogue No. 232000531P
Pages 48
Language English; Aussi disponible en français
Price $38.40

Published by the Organization for Economic Co-operation and Development, 2000.


This report recommends that Article 14 be eliminated from the OECD’s Model Tax Convention on Income and Capital and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence. The taxation of professional services and other activities of an independent character under Article 14 of the OECD Model Tax Convention is problematic. For example, what activities and entities fall within Article 14 as opposed to the business profits Article (Article 7)? Is the distinction between those activities and entities satisfactory and easy to apply? What are the practical differences between taxation under Article 7 and 14?

This report analyses those questions in detail and concludes that there is no practical difference between the two Articles or if any differences did in fact exist, there is no valid policy justification for them.

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This page last modified: May 15, 2000

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