The online commentary on Art. 7 (Business Profits) extensively discusses several important and intricate issues. It covers a large number of court decisions from many jurisdictions.
The discussion is designed and structured for professionals in law firms, accounting firms, and multinational corporations across the world.
The Commentary is divided into the following chapters:
- Source rule;
- The Basic Rule of Art. 7;
- Limited force of attraction rule;
- Residence country taxation;
- Income characterization;
- Independent enterprise hypothesis (Art. 7(2));
- Income attribution;
- Computation methods;
- Composite contracts;
- Presumptive taxation;
- Expense deduction;
- Renvoi clause;
- Rule of consistency; and
- Special versus general rules.