Shows
TaxbeechArticle 13 of MLI | Exceptions to PEArticle 13 of the MLI modifies Article 5(4) of the OECD Model Tax Convention, which deals with a list of exceptions that do not constitute a Permanent Establishment. The rationale behind creating an exception list is that all activities mentioned in the list have a preparatory or auxiliary character that is not enough to establish a significant economic presence in another jurisdiction.
This episode is also available as a blog post: https://taxbeech.com/2021/06/29/complete-guide-on-article-13-of-mli/
2021-06-2907 minTaxbeechArticle 12 of MLI | Artificial Avoidance of PE through Commissionnaire ArrangementsThis episode is also available as a blog post: https://taxbeech.com/2021/06/15/article-12-of-mli-artificial-avoidance-of-pe-through-commissionnaire-arrangements/
2021-06-1505 minTaxbeechArticle 11 of MLI | Country’s right to tax its residents – Savings ClauseThis episode is also available as a blog post: https://taxbeech.com/2021/06/04/article-11-of-mli-countrys-right-to-tax-its-residents-savings-clause/
2021-06-0404 minTaxbeechUnderstanding Compatibility ClauseThis episode is also available as a blog post: https://taxbeech.com/2021/01/13/understanding-compatibility-clause/
2021-06-0202 minTaxbeechArticle 10 of MLI – PE Triangular CaseThis episode is also available as a blog post: https://taxbeech.com/2021/06/02/article-10-of-mli-pe-triangular-case/
2021-06-0210 minTaxbeechEverything about Triangular CasesThis episode is also available as a blog post: https://taxbeech.com/2021/05/06/everything-about-triangular-cases/
2021-05-0605 minTaxbeechCapital Gains from Alienation of Shares or Interests – Article 9 of MLIThis episode is also available as a blog post: https://taxbeech.com/2021/05/05/capital-gains-from-alienation-of-shares-or-interests-article-9-of-mli/
2021-05-0512 minTaxbeechDividend Transfer Transactions – Article 8 of MLIThis episode is also available as a blog post: https://taxbeech.com/2021/05/04/dividend-transfer-transactions-article-8-of-mli/
2021-05-0407 minTaxbeechEverything about Simplified Limitation of Benefits | SLOB TestThis episode is also available as a blog post: https://taxbeech.com/2021/05/01/everything-about-simplified-limitation-of-benefits-slob-test/
2021-05-0118 minTaxbeechPrincipal Purpose Test | Paragraph 1 of Article 7 of MLIThis episode is also available as a blog post: https://taxbeech.com/2021/04/30/principal-purpose-test-article-71-of-mli/
2021-04-3007 minTaxbeechArticle 6 of MLI – Purpose of Covered Tax AgreementThis episode is also available as a blog post: https://taxbeech.com/2021/04/29/article-6-of-mli-purpose-of-covered-tax-agreement/
2021-04-2909 minTaxbeechArticle 5 of Multilateral Instruments | Application of Methods for Elimination of Double TaxationThis episode is also available as a blog post: https://taxbeech.com/2021/04/28/article-5-of-multilateral-instruments-application-of-methods-for-elimination-of-double-taxation/
2021-04-2814 minTaxbeechArticle 4 of MLI | Dual Resident EntitiesThis episode is also available as a blog post: https://taxbeech.com/2021/04/23/article-4-of-mli-dual-resident-entities/
2021-04-2308 min
TaxbeechArticle 1 and 2 of Multilateral ConventionThis episode is also available as a blog post: https://taxbeech.com/2021/03/15/article-1-and-2-of-multilateral-convention/
2021-03-1703 min
TaxbeechArticle 3(1) of MLI – Taxation of income derived by or through fiscally transparent entitiesThis episode is also available as a blog post: https://taxbeech.com/2021/03/17/article-31-of-mli-taxation-of-income-derived-by-or-through-fiscally-transparent-entities/
2021-03-1703 min