Published: 2022-04-11
Articles
Understanding the OECD Model of Tax Convention: The Lesson of History
1–49
AbstractAn important recent development in international taxation is the publication of the OEEC (the forerunner of the OECD when it was a purely...
The New OECD Approach on Profit Allocation: A Step Forward Towards Neutral Treatment of Permanent Establishments and Subsidiaries
51–76
AbstractOne of the vexing questions in tax law is whether or not the legal form should make a difference in taxing companies. This question arises...