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To learn about cross border taxation
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Article 13 of MLI | Exceptions to PE
Article 13 of the MLI modifies Article 5(4) of the OECD Model Tax Convention, which deals with a list of exceptions that do not constitute a Permanent Establishment. The rationale behind creating an exception list is that all activities mentioned in the list have a preparatory or auxiliary character that is not enough to establish a significant economic presence in another jurisdiction.
This episode is also available as a blog post: https://taxbeech.com/2021/06/29/complete-guide-on-article-13-of-mli/ -
Article 12 of MLI | Artificial Avoidance of PE through Commissionnaire Arrangements
This episode is also available as a blog post: https://taxbeech.com/2021/06/15/article-12-of-mli-artificial-avoidance-of-pe-through-commissionnaire-arrangements/
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Article 11 of MLI | Country’s right to tax its residents – Savings Clause
This episode is also available as a blog post: https://taxbeech.com/2021/06/04/article-11-of-mli-countrys-right-to-tax-its-residents-savings-clause/
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Understanding Compatibility Clause
This episode is also available as a blog post: https://taxbeech.com/2021/01/13/understanding-compatibility-clause/
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Article 10 of MLI – PE Triangular Case
This episode is also available as a blog post: https://taxbeech.com/2021/06/02/article-10-of-mli-pe-triangular-case/
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Everything about Triangular Cases
This episode is also available as a blog post: https://taxbeech.com/2021/05/06/everything-about-triangular-cases/