Everything about Triangular Cases


We have repeatedly discussed how corporate and multinational entities have creatively used the tax treaties to reduce their overall tax liabilities. One such measure is a typical “Triangular case” where three countries are involved, the State of residence of the entity, the State of the Source, and the State where the Permanent establishment is resident … Continue reading Everything about Triangular Cases

OECD Model Tax Treaty: Article 3


Article 3 of the OECD Model Tax treaty concerns the general definition used throughout the Convention. Important terms like a resident and permanent establishment are defined in separate Articles (Article 4 and 5 respectively), whereas specific articles define few.  Today we will discuss the following points : List of terms provided under Article 3 of … Continue reading OECD Model Tax Treaty: Article 3