A Construction Consortium as a Permanent Establishment from an International Tax Law Perspective: Inconsistencies and Deficiencies in Article 5(3) of the OECD Model and Commentary

In this article, the author considers key difficulties in the interpretation and application of article 5(3), in conjunction with article 7, of the OECD Model regarding the taxation of a non-resident investor forming a joint-venture with a resident enterprise to undertake a substantial construction or infrastructure project in the latter’s residence state.