2008 was a significant year for scholars interested in the history of tax treaties. Apart from the Rust tax treaties history conference, the main event was the release of the OECD archives in September when the OECD celebrated the 50th anniversary of the OECD Model (or more accurately the...

The current rules in tax treaties for business profits of permanent establishments (PEs) have recently received their greatest alteration since they were created in the 1950s as a result of the Report on Attribution of Profits to Permanent Establishments representing over a decade of work by the...

This article analyses the policy, historical development and current application of permanent establishment rules for travellers. It is readily accepted that pedlars and itinerant merchants do not give rise to permanent establishments but after many years of the agency permanent establishment...

This paper consider the history of the tax treaty rule on royalties up to the emergence of the modern form, the borders of the provision and the fundamental question of why we have it (viewed from an historical perspective). In the modern context of the OECD Model with zero taxation at source on...

The publication of the OECD Model tax treaty in 1977 marked 50 years of development. The Model seeks to remove international tax barriers by reconciliation at the interface of tax systems and has produced a bilateral network because it is generally considered that the diversity of tax systems...

This article considers the recent final (non) report of the Australian Business Tax Working Group which was set up to review how to finance a cut to the corporate income tax rate and/or whether Australia should adopt an allowance for corporate equity or other structural reform to the corporate...

The OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) is receiving significant attention from taxpayers and national governments. Because the action plan is about action, it contains little discussion of the tax policy questions involved. One of the less-noticed aspects of the plan...