This report recommends that Article 14 be
eliminated from the OECDs 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. Published
by the Organization for Economic Co-operation and Development, 2000. |
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