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The
Technical Advisory Group on Monitoring the Application
of Existing Treaty Norms for Taxing Business Profits (the
"Business Profits TAG") was set up by the Committee on
Fiscal Affairs in January 1999 with the general
mandate to “examine how the current treaty rules for
the taxation of business profits apply in the context
of electronic commerce and examine proposals for
alternative rules”. The Business Profits TAG's work
resulted in discussion drafts on “Attribution of
Profit to a Permanent Establishment Involved in
Electronic Commerce Transactions”, which was released
in February 2001, and “Place of Effective Management
Concept: Suggestions for Changes to the OECD Model Tax
Convention”, released in May 2003. This final report,
which was prepared in light of comments received on a
first draft and was presented to the Committee on
Fiscal Affairs in June 2004, deals with the remaining
elements of the work programme of the TAG. It examines
some of the new business models that have served as
background for the TAG’s analysis, summarizes the
existing treaty rules for taxing business profits,
presents a critical evaluation of these current rules,
examines some alternatives and, finally, presents the
conclusions and recommendations of the TAG.
Final report of the
Technical Advisory Group on Monitoring the Application
of Existing Treaty Norms for Taxing Business Profits.
disponible à l'adresse :
http://www.oecd.org/dataoecd/58/53/35869032.pdf
publié
le 06/02/06 |
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