Oecd model tax treaty commentary permanent establishment

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  5. Commentary on Article 5: Concerning the Definition of Permanent Establishment

Model Tax Convention on Income and on Capital 2017 (Full Version)

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This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, the Recommendation of the OECD Council, the historical notes and the background reports.

The full version of the OECD Model Tax Convention is published regularly to reflect updates.

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