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Remove Comments from the Tax Agreement

Remove Comments from the Tax Agreement

Aug 6th, 2022

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Got questions?

Below are some common questions from our customers that may provide you with the answer you're looking for. If you can't find an answer to your question, please don't hesitate to reach out to us.

What is Article 4 of the OECD model?

4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

What is Article 7 paragraph 1 of the tax treaty?

(1) The business profits of an enterprise of one of the Contracting States shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.

What is the Article 5 of the tax treaty?

5. No profits shall be attributed to a permanent establishment by reason of the mere purchase by that permanent establishment of goods or merchandise for the enterprise.

What is the Article 11 interest?

Paragraph 1 of Article 11 lays down the principle that interest arising in a Contracting State (say country S) and paid to a resident of the other Contracting State (say Country R) may be taxed in that other state (i.e. in country R). Right to taxation by the Country S usually subject to a limit usually 10% or 15%.

What is the OECD model?

The OECD Model Tax Convention on Income and on Capital (the OECD Model) provides a means of settling on a uniform basis the most common problems that arise in the field of international juridical double taxation.

What is the Article 12 of the tax treaty?

Article 12: Royalties Royalties derived and beneficially owned by a resident of a Contracting State shall be taxable only in that State. 2.

What is Article 7 of OECD Guidelines?

1. Profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.

What is the principal purpose test?

By means of the principal purpose test, the tax administration can deny the tax treaty benefit if one of the principal purposes of the action undertaken by the taxpayer was to obtain a benefit.

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