On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the Transfer Pricing Aspects of Intangibles. The comments received in response to this invitation have been published. This edition replaces the previous edition rele…
drept fiscal
Revised complete edition of public comments received on the discussion draft on Safe Harbours
On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the revision of the Safe Harbours Section in Chapter IV of the Transfer Pricing Guidelines. The comments received in response to this invitation have been published. T…
Revised complete edition of public comments received on the discussion draft on timing issues relating to transfer pricing
On 6 June 2012, the OECD released an invitation to comment on a discussion draft on timing issues relating to transfer pricing. The comments received in response to this invitation have been published. This edition replaces the previous edition releas…
OECD Model Tax Convention: revised discussion draft on tax treaty issues related to emissions permits and credits
The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on tax treaty issues related to emissions permits/credits, which addresses the application of the provisions of the OECD Model Tax Convention to the cross-border…
OECD Model Tax Convention: revised discussion draft on the definition of “permanent establishment”
The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on the definition of “permanent establishment” that is included in Article 5 of the OECD Model Tax Convention.
OECD Model Tax Convention: revised discussion draft on the meaning of “beneficial owner”
The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on the meaning of “beneficial owner”, a term that is used in Articles 10, 11 and 12 of the OECD Model Tax Convention.