Triangular cases : Art. 15 of the OECD Model, income from employment and the definition of terms

This note considers a recent Danish tax case that involved the interpretation of Art. 15 of the OECD Model Convention regarding employees' remuneration and the definition of the term "permanent establishment". In this respect, the author specifically comments on tax treaties and the interpretation of treaties with regard to the Vienna Convention on the Law of Treaties of 23 May 1969.