Issues Related to Article 14 of the
OECD Model Tax Convention (Issues in International Taxation Series No. 7)
|Language||English; Aussi disponible en français|
Published by the Organization for Economic Co-operation and Development, 2000.
|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.
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This page last modified: May 15, 2000
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