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The new draft of Article 7 (Business Profits) – first thoughts
Published on 01 Jun 09 by "THE TAX SPECIALIST" JOURNAL ARTICLE
This article considers the key aspects of the draft Article 7 and commentary focusing on the issue of eliminating double taxation and the introduction of the concept of free capital. The OECD’s stated objectives are to provide greater certainty and clarity in the interpretation of Article 7 and whilst the objectives have not fully been met, this “first draft” has been received with optimism. It will be interesting to see whether the OECD will pull back on its use of broad concepts in its updated draft or whether the pendulum will swing towards more prescriptive drafting in light of submissions received from the OECD community.
Author profile
Neil Pereira CTA
Neil is a Tax and Legal Partner with more than 20 years of international tax advisory and structuring experience for multinational clients across a range of industries. Neil’s extensive experience includes leading multidisciplinary teams on tax planning and due diligence for corporate reorganisations, legal entity reduction and consolidation of Australian operations for tax and broader business model and supply chain optimisation. Neil has advised clients on the Australian tax and legal implications of setting up business structures, share and business transfers, IP migration, foreign investment review board as well as regulatory and tax compliance for multinational groups. - Current at 25 July 2022
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