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Working Papers


  • 29-April-2003

    English

    OECD Launches Project on Improving the Resolution of Cross-Border Tax Disputes

    The OECD has launched a major project to improve the effectiveness of the Mutual Agreement Procedure (MAP) of Article 25 of the OECD Model Tax Convention.

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  • 29-April-2003

    English

    Transfer Pricing: The OECD launches an invitation to comment on comparability issues; public comments received

    As part of its procedures for monitoring the implementation of the 1995 Transfer Pricing Guidelines, the Working Party No. 6 of the OECD Committee on Fiscal Affairs has selected two areas to be considered in priority.

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  • 4-March-2003

    English

    Attribution of Profits to a Permanent Establishment (PE): the OECD releases two further Discussion Drafts for public comment on 4 March 2003

    The 2003 Discussion Drafts address one of the most complex areas in international taxation, i.e. how to determine the taxing rights of a country where an enterprise that is resident of another country undertakes business through a permanent estab...

  • 4-March-2003

    English, , 312kb

    Discussion Draft on the Attribution of Profits to Permanent Establishments: Part III (Global Trading of Financial Instruments

    Part III is dedicated to the global trading of financial instruments. The starting point for this analysis is naturally the 1998 OECD document "The taxation of Global Trading of Financial Instruments", which has been updated to take into consider...

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  • 15-March-2002

    English

  • 8-February-2001

    English, , 417kb

    Discussion Draft: Attribution of Profit to a Permanent Establishment

    There is a considerable variation in the domestic laws of OECD Member countries regarding the taxation of Permanent Establishment. There is no consensus amongst the OECD Member countries with regards the interpretation of Article 7 of the OECD M...

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