The Object of Art. 9(1) of the OECD Model Convention: Commercial or Financial Relations

This article examines two dimensions of the concept of a controlled transaction under Art. 9(1) of the OECD Model. The first part is an examination of the basic object qualification under Art. 9(1), treaty-based limits on the object qualification and the OECD position. Second, the delimitation of the controlled transaction for purpose of the arm’s length test under Art. 9(1) is examined.