OECD model tax convention - Revision history

imported>Doug Williamson: Add link.

2022-07-06T08:47:22Z

Add link.

← Older revision		Revision as of 08:47, 6 July 2022
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	* [[Profit shifting]]		* [[Profit shifting]]
	* [[Residence]]		* [[Residence]]
			* [[Tax ]]

	[[Category:Accounting,_tax_and_regulation]]		[[Category:Accounting,_tax_and_regulation]]

imported>Doug Williamson: Add link.

2022-07-04T21:07:17Z

Add link.

← Older revision		Revision as of 21:07, 4 July 2022
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	* [[Double tax treaties]]		* [[Double tax treaties]]
	* [[Double taxation]]		* [[Double taxation]]
			* [[Model]]
	* [[Organisation for Economic Co-operation and Development]]		* [[Organisation for Economic Co-operation and Development]]
	* [[Permanent establishment]]		* [[Permanent establishment]]

imported>Doug Williamson: Layout.

2022-02-26T20:35:29Z

Layout.

← Older revision		Revision as of 20:35, 26 February 2022
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	Companies often operate in a number of different countries and, as a result, may be resident in more than one country under the different domestic tax laws of each country.		Companies often operate in a number of different countries and, as a result, may be resident in more than one country under the different domestic tax laws of each country.

	Many developed countries have entered into bilateral international tax agreements, known as double tax treaties, with other countries~~. Many, but not all, of the tax treaties follow the OECD model tax convention~~.		Many developed countries have entered into bilateral international tax agreements, known as double tax treaties, with other countries.

			Many, but not all, of the tax treaties follow the OECD model tax convention.

	The OECD model convention provides a basis that can be used to draw up a bilateral tax agreement between two states, that seeks to eliminate double taxation. Double tax treaties also help to encourage cross border trade.
			The OECD model convention provides a basis that can be used to draw up a bilateral tax agreement between two states, that seeks to eliminate double taxation.

			Double tax treaties also help to encourage cross border trade.


	The OECD model tax convention contains a 'tie breaker' clause that determines a company’s tax residence for the purposes of the treaty.		The OECD model tax convention contains a 'tie breaker' clause that determines a company’s tax residence for the purposes of the treaty.

	This is taken to be the place where ‘effective management’ and control (POEM) is carried on. In a tie context this test requires a review of where the day to day management of the company takes place.		This is taken to be the place where ‘effective management’ and control (POEM) is carried on.

			In a tie context this test requires a review of where the day to day management of the company takes place.

imported>Doug Williamson: Classify page.

2021-12-16T11:58:59Z

Classify page.

@@ Line 15: / Line 15: @@
 == See also ==
 * [[Double tax treaties]]
 * [[Double taxation]]
@@ Line 22: / Line 23: @@
 * [[Profit shifting]]
 * [[Residence]]

imported>Doug Williamson: Create the page. Source ACT CertFin CT 3.1.1 pages 10 to 11.

2015-05-24T09:54:15Z

Create the page. Source ACT CertFin CT 3.1.1 pages 10 to 11.

New page

''Tax''.

Companies often operate in a number of different countries and, as a result, may be resident in more than one country under the different domestic tax laws of each country.

Many developed countries have entered into bilateral international tax agreements, known as double tax treaties, with other countries. Many, but not all, of the tax treaties follow the OECD model tax convention.

The OECD model convention provides a basis that can be used to draw up a bilateral tax agreement between two states, that seeks to eliminate double taxation. Double tax treaties also help to encourage cross border trade.

The OECD model tax convention contains a 'tie breaker' clause that determines a company’s tax residence for the purposes of the treaty.

This is taken to be the place where ‘effective management’ and control (POEM) is carried on. In a tie context this test requires a review of where the day to day management of the company takes place.

== See also ==
* [[Double tax treaties]]
* [[Double taxation]]
* [[Organisation for Economic Co-operation and Development]]
* [[Permanent establishment]]
* [[POEM]]
* [[Profit shifting]]
* [[Residence]]