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- catalog abstract "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. It recommends that Article 14 be eliminated from the Model and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence.".
- catalog contributor b11734578.
- catalog created "c2000.".
- catalog date "2000".
- catalog date "c2000.".
- catalog dateCopyrighted "c2000.".
- catalog description "Introduction -- I. The Elimination of Article 14 -- II. Which Activities Fall within Article 14 -- III. Which Entities Fall within Article 14 -- IV. What are the Practical Differences Concerning Taxation under Articles 7 and 14 -- a)Are there differences between the concepts of "permanent establishment" and "fixed base"? -- b) Does Article 14 restrict source taxation to income from services performed personally by the taxpayer? -- c) Are the specific rules of Paragraph 2-7 of Article 7 rules applicable to Article 14? -- d) Are there differences in the source taxation rights granted under Article 7 and 14? -- e) Does the distinction between Articles 7 and 14 have any impact on domestic law distinctions? -- V. Does the Elimination of Article 14 Require Changes to Article 7? -- Annex -- Changes to the Articles -- Changes to the Commentary".
- catalog description "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. It recommends that Article 14 be eliminated from the Model and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence.".
- catalog extent "45 p. ;".
- catalog identifier "9264176438".
- catalog isPartOf "Issues in International Taxation, 1990-0368 ; no.7.".
- catalog isPartOf "Issues in international taxation ; no. 7".
- catalog issued "2000".
- catalog issued "c2000.".
- catalog language "eng".
- catalog publisher "Paris : Organisation for Economic Co-operation and Development,".
- catalog subject "330 1".
- catalog subject "K4487.P76 I85 2000".
- catalog subject "Professions Taxation Law and legislation.".
- catalog subject "Taxation".
- catalog tableOfContents "Introduction -- I. The Elimination of Article 14 -- II. Which Activities Fall within Article 14 -- III. Which Entities Fall within Article 14 -- IV. What are the Practical Differences Concerning Taxation under Articles 7 and 14 -- a)Are there differences between the concepts of "permanent establishment" and "fixed base"? -- b) Does Article 14 restrict source taxation to income from services performed personally by the taxpayer? -- c) Are the specific rules of Paragraph 2-7 of Article 7 rules applicable to Article 14? -- d) Are there differences in the source taxation rights granted under Article 7 and 14? -- e) Does the distinction between Articles 7 and 14 have any impact on domestic law distinctions? -- V. Does the Elimination of Article 14 Require Changes to Article 7? -- Annex -- Changes to the Articles -- Changes to the Commentary".
- catalog title "Issues related to Article 14 of the OECD model tax convention.".
- catalog type "text".