International - Internal Interest Dealings for Financial and Non-Financial Enterprises and Art. 7 of the OECD Model Tax Convention
- P. Hoogterp
- International Transfer Pricing Journal, 2009 (Volume 16), No 6
- 8 October 2009
This article presents an overview of the implications of the conclusions of the OECD Report on the Attribution of Profits to Permanent Establishments with regard to internal interest dealings for both financial enterprises (for the interpretation of existing treaties based on the current text of Art. 7 of the OECD Model) and non-financial enterprises (for the interpretation of future tax treaties or future amendments to existing treaties based on the text of the Draft new Art. 7).