By Organisation for Economic Co-Operation and Development

ISBN-10: 9264099905

ISBN-13: 9789264099906

Booklet through organization for financial Co-Operation and improvement

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Additional resources for 2002 Reports Related to the Oecd Model Tax Convention: Issues in International Taxation

Sample text

The customer will not have possession or control over the equipment and will utilise the equipment concurrently with other customers. 4. Provision of services Analysis and conclusions 29. Whilst the OECD Model Tax Convention does not deal separately with payments for the provision of services, the distinction between these payments and payments made as consideration for the acquisition of property is relevant for certain bilateral conventions as well as for some domestic tax law purposes. The Committee therefore considered it useful to discuss the distinction between the provision of services and transactions resulting in the acquisition of property, noting that the preceding subsection already dealt with the particular question of the distinction between a rental of property and the provision of services.

35. 1 For these reasons, it was decided to restrict the analysis to that definition so as to try to clarify the limits of application of these provisions. e. technical services, managerial services and consultancy services. i) Technical services 36. Services are of technical nature when special skills or knowledge related to a technical field are required for the provision of such services. Whilst techniques related 1. See, for example, the provision of the India-United States tax convention dealing with “included services”.

The Committee therefore concluded that the following changes should be made to the Commentary on Article 12 of the OECD Model Tax Convention: Replace the last sentence of paragraph 11 of the Commentary on Article 12 by the following (changes to the existing text appear in strikethrough and bold italics): “If, however, one part of what is being provided constitutes by far the principal purpose of the contract and the other parts stipulated therein are only of an ancillary and largely unimportant character, then the treatment applicable to the principal part should generally be applied to the whole amount of the consideration.

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