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OECD releases a revised discussion draft of Part I (General) for public comment on 3 August 2004 and provides progress report on Parts II-IV. Written comments should be submitted no later than 28 September 2004.
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.
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...
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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
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Attributing Financial Assets: Importance of the Sales/Trading Function. Example Where Loan Booking Jurisdiction is not in Line with Functional Analysis
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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?
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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.
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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...