United Nations
Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is, the state of residence has the primary right to tax with source state entitlement restricted to taxing the profits of permanent establishments. Source…
There are a lot of opinions on multinationals and their tax practices. One conventional perception is that multinationals have a general tax advantage over their domestic competitors as their international operations allow for substantial tax management to minimize the corporate tax burden at group level. A number of tax policy projects are in process and…
When internationally mobile workers retire, they look to Art 18 of the OECD Model tax treaty to determine their tax treatment if they are private sector workers. Government workers look to Art 19. What about employees of international organisations? Although international civil servants, they work for no government and are outside Art 19. Commonly, treaties…
