|
By Oliver R. Hoor*
On 22 July 2010, the OECD approved the 2010 update to the OECD Model Tax Convention. This update includes a new Article 7 (Business Profits), which completes the Committee’s work on the attribution of profits to permanent establishments. It also introduces new text related to the granting of tax treaty benefits with respect to the income of collective investment vehicles, the application of tax treaties on State-owned entities (including sovereign wealth funds), tax treaty issues related to common telecommunications transactions, and the application of Article 15 (Income from Employment) to employees who work for a short duration in a foreign country.
I. Introduction
Most tax treaties worldwide including those concluded by...
|