Territorial connection (or its more fashionable name “nexus”) for tax purposes is expressed in a variety of ways in domestic and international legal instruments. Permanent establishment in article 5 of the Model treaties and “fixed base” in article 14 of the UN Model are central concepts in direct tax subject matter jurisdiction. Fixed establishment The…

The right to be free from discrimination is perhaps the single most important human right as indicated by the fact that it appears as the first article in the UN Universal Declaration of Human Rights: “All human beings are born free and equal in dignity and rights.” In the field of international taxation, article 24…

Apropos Molinos Rio de la Plata SA 1. Background: Memorandum DNI 799/10 In Memorandum 799/10, the Argentine Competent Authority (Argentine Tax Directorate, Dirección Nacional de Impuestos or DNI) dealt with a DTA structured after the Andean Model Treaty (AMT) and the interposition of a Chilean holding company (Platform Company) by an Argentine ultimate corporate shareholder….