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Is Article 5 of the OECD's Model Tax Convention still fit for purpose given the changes in world trade since the Article was fir
Finance & Accounting
Pages 8 (2008 words)
The definition of Permanent Establishment Article 5 of the OECD Model Tax Convention 1. Introduction Personal and Corporate Income Tax and the tax on Goods and Services are the largest sources of revenue for governments around the world. For the fiscal year 2012-13, the total tax revenues for the UK are forecast at ?
Raising personal income taxes or the goods and services tax any further would be extremely unpopular with the people. There is widespread anger in the UK and in other OECD countries about the tax avoidance practices of large multinational corporations. In the UK, the Public Accounts Committee of Parliament questioned senior executives of Starbucks, Amazon and Google on their tax avoidance practices which were held to be against the spirit if not the letter of the law 2. Multinational Corporations (MNC) accounted for over $33 trillion in global sales in 2010 with a value addition of over $16 trillion, representing one-quarter of the world GDP. Many of the MNC from the Fortune 100 list have bigger revenues than several of the emerging economy countries around the world and most of these MNC are headquartered in the OECD countries 3. 1 Browne, J. and Roantree, B., “A Survey of the UK Tax System”, IFS Briefing Note BN09, October 2012. accessed 20 March 2013. 2 Knight, L., “Corporate tax avoidance: How do companies do it?” BBC News, 4 Dec 2012. < http://www.bbc.co.uk > accessed on 20 March 2013. 3 UNCTAD Report, “World Investment Report 2011”, United Nations Conference on Trade and Development < http://www.imf.org > accessed on 20 March 2013. ...
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