TaxbeechJun 29, 2021
00:00
07:39
Article 13 of MLI | Exceptions to PE
Article 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/
Jun 29, 202107:39
Article 12 of MLI | Artificial Avoidance of PE through Commissionnaire Arrangements
This episode is also available as a blog post: taxbeech.com/2021/06/15/article-12-of-mli-artificial-avoidance-of-pe-through-commissionnaire-arrangements/
Jun 15, 202105:14
Article 11 of MLI | Country’s right to tax its residents – Savings Clause
This episode is also available as a blog post: taxbeech.com/2021/06/04/article-11-of-mli-countrys-right-to-tax-its-residents-savings-clause/
Jun 04, 202104:10
Understanding Compatibility Clause
This episode is also available as a blog post: taxbeech.com/2021/01/13/understanding-compatibility-clause/
Jun 02, 202102:29
Article 10 of MLI – PE Triangular Case
This episode is also available as a blog post: taxbeech.com/2021/06/02/article-10-of-mli-pe-triangular-case/
Jun 02, 202110:27
Everything about Triangular Cases
This episode is also available as a blog post: taxbeech.com/2021/05/06/everything-about-triangular-cases/
May 06, 202105:25
Capital Gains from Alienation of Shares or Interests – Article 9 of MLI
This episode is also available as a blog post: taxbeech.com/2021/05/05/capital-gains-from-alienation-of-shares-or-interests-article-9-of-mli/
May 05, 202112:46
Dividend Transfer Transactions – Article 8 of MLI
This episode is also available as a blog post: taxbeech.com/2021/05/04/dividend-transfer-transactions-article-8-of-mli/
May 04, 202107:00
Everything about Simplified Limitation of Benefits | SLOB Test
This episode is also available as a blog post: taxbeech.com/2021/05/01/everything-about-simplified-limitation-of-benefits-slob-test/
May 01, 202118:10
Principal Purpose Test | Paragraph 1 of Article 7 of MLI
This episode is also available as a blog post: taxbeech.com/2021/04/30/principal-purpose-test-article-71-of-mli/
Apr 30, 202107:09
Article 6 of MLI – Purpose of Covered Tax Agreement
This episode is also available as a blog post: taxbeech.com/2021/04/29/article-6-of-mli-purpose-of-covered-tax-agreement/
Apr 29, 202109:17
Article 5 of Multilateral Instruments | Application of Methods for Elimination of Double Taxation
This episode is also available as a blog post: taxbeech.com/2021/04/28/article-5-of-multilateral-instruments-application-of-methods-for-elimination-of-double-taxation/
Apr 28, 202114:10
Article 4 of MLI | Dual Resident Entities
This episode is also available as a blog post: taxbeech.com/2021/04/23/article-4-of-mli-dual-resident-entities/
Apr 23, 202108:04
Article 1 and 2 of Multilateral Convention
This episode is also available as a blog post: taxbeech.com/2021/03/15/article-1-and-2-of-multilateral-convention/
Mar 17, 202103:19
Article 3(1) of MLI – Taxation of income derived by or through fiscally transparent entities
This episode is also available as a blog post: taxbeech.com/2021/03/17/article-31-of-mli-taxation-of-income-derived-by-or-through-fiscally-transparent-entities/
Mar 17, 202103:21