OECD Model, art. 7 provides that the profits of any business carried on by an enterprise of country A are taxable only in country A unless the business is carried on in country B through a ‘permanent establishment’ in that country.

For the detailed discussion of this term ‘permanent establishment’ (covered by OECD Model, art. 5), including developments arising out of the OECD/G20 BEPS project, see ¶170-600 and Schwarz on Tax Treaties ¶18-050.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.