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English, , 312kb
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...
Article for the OECD's Observer, written by John Neighbour from the Centre for Tax Policy and Administration
English, , 21kb
Attributing Financial Assets: Importance of the Sales/Trading Function. Example Where Loan Booking Jurisdiction is not in Line with Functional Analysis
English, , 17kb
Relating to the general situation ( Part 1): A permanent establishment is engaged in Research and Development activities leading to the development of intangible property rights. How should dealings be recognised and characterized?
English, , 21kb
Functional analysis, recognition of dealings, characterisation of dealings, attribution of capital to a Banking Permanent Establishment, split functions.
The public comments which were received on Part I (General Considerations ) and Part II (Banks) of the 2001 discussion draft on the Attribution of Profits to Permanent Establishments.
English, , 417kb
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...
In October 1999, the OECD releases the update to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.