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  Miscellaneous 2003

The Attribution of Profits and Capital Structure to a Permanent Establishment under the OECD Model Tax Treaty

Source: Australian Tax Forum Journal Article

Published Date: 1 Jul 2003

 
This paper considers the attribution of profits to a permanent establishment under Article 7 of the OECD Model Tax Convention on Income and on Capital (Model Treaty) 1 with particular reference to the recognition of internal dealings, profits and capital structure of the taxable entity and its branches.
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