https://www.taxtmi.com/manuals?id=2926 Revisions to the OECD Model treat intermediaries whose activities are intended to result in the regular conclusion of contracts for a foreign enterprise as creating a taxable presence unless the intermediary is an independent business; Article 5(5) and 5(6) amendments and an anti-fragmentation rule narrow preparatory or auxiliary exceptions and aggregate cohesive activities of closely related entities, with implementation through the multilateral instrument and domestic alignment to ensure attribution and effectiveness of PE rules. en-us Mon, 26 Jun 2023 13:19:00 +0530 Sat, 27 Jan 2024 13:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/manuals?id=2926 Revisions to the OECD Model treat intermediaries whose activities are intended to result in the regular conclusion of contracts for a foreign enterprise as creating a taxable presence unless the intermediary is an independent business; Article 5(5) and 5(6) amendments and an anti-fragmentation rule narrow preparatory or auxiliary exceptions and aggregate cohesive activities of closely related entities, with implementation through the multilateral instrument and domestic alignment to ensure attribution and effectiveness of PE rules. Manuals Income Tax Mon, 26 Jun 2023 13:19:00 +0530 https://www.taxtmi.com/manuals?id=2926