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Discussion Draft on a New Art. 7 of the OECD Model Convention

M.C. Bennett; R. (Raffaele) Russo
International Transfer Pricing Journal, 2009 (Volume 16), No 2
1 March 2009
This article provides an overview of the discussion draft on a new Art. 7 of the OECD Model Tax Convention (OECD Model), which was released in July 2008. It describes the background to the discussion draft, the new Art. 7 and its Commentary, and the proposed consequential changes to other parts of the OECD Model. It is expected that, once finalized, the proposed changes will be included in the next update of the OECD Model.
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