The OECD's public discussion draft ‘BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances' proposed a series of rules for the OECD model. The draft for Article X, ‘‘Entitlement to Benefits,'' the first five paragraphs of which are described therein as...

The relevance of the commentaries on the OECD and UN models for the interpretation of the UN model /David Orzechowski --Business profits, permanent establishments and associated enterprises /Raffaele Petruzzi and Viktoria Wöhrer --Independent and dependent personal services /Benjamin Walker and...

Since its announcement in 2013, the Belt and Road Initiative (BRI), also known as the New Silk Road, has gradually gained international recognition. The New Silk Road project has a potential to transform the global flows of trade and investment. It is increasingly recognized that tax has the...

Tax policy has always been a predominant element of national economic policies and a decisive tool in directing the actions of governments in the economic field. In the past decade, however, as an increasingly globalized economy has presented challenges, tax policy has gained new importance...