Agency Permanent Establishments: in the name of and the Relationship between Article 5(5) and (6) – Part 1

In this first part of a two-part article, the author sets out his interpretation of the term “in the name of”/“binding” and the relationship between article 5(5) and (6) of the OECD Model. The second part will be published in the February 2013 Issue of the Bulletin for International Taxation.