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:
- Introduction;
- Definition of "resident";
- Fiscally transparent entities;
- Liable to tax: can domestic tax law meaning of that expression be read into Art. 4(1) of a tax treaty?
- Art. 4(2): tie-breaker rules for individuals; and
- Art. 4(3): tie-breaker rules for non-individuals.