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The revised draft of Article 7 Business Profits – on second thoughts…

The Tax Specialist | 1 Apr 10
 
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Published on 01 Apr 10 by "THE TAX SPECIALIST" JOURNAL ARTICLE

The OECD released a revised draft of Article 7 and its commentary in November 2009 based on consultation with professional bodies and representatives from the business community. The most important change in this second draft is the replacement of the paragraph dealing with double taxation in relation to free capital with a much broader provision, although the concept of free capital itself remains. A key measure will be effective implementation of these provisions by Competent Authorities.

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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