Tax treaty negotiators in 100 countries will be tied up over the next few months with the challenge to evaluate their positions on the BEPS Multilateral Convention (BEPS Convention) with a view to…
Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…
Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is,…
