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  3. Revised Commentary on Existing Article 5 - Permanent Establishment

Revised Commentary on Existing Article 5 - Permanent Establishment

Revised Commentary on Existing Article 5 - Permanent Establishment 

Revision to Article 5 - Permanent Establishment.pdf
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Topic

Tax Cooperation
Domestic Public Resources

Type

Other

Official status

Document

Year

2008
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  • Home
  • About
    • About Financing for Sustainable Development Office
    • Meet the Director
    • History of financing for development
    • Office Directory
    • What is financing for sustainable development?
  • FFD4
  • Tax
    • UN Framework Convention on International Tax Cooperation (UNFCITC)
      • Intergovernmental Negotiating Committee (INC)
        • Background and Key Documents
        • Fourth Session
        • Third Session
          • Inputs
        • Structure
        • Participation
        • Organizational Session
        • First and Second Sessions
          • Inputs
      • Ad Hoc Committee to Draft Terms of Reference
        • Bureau
        • Organizational Session
        • First Session
          • Inputs
        • Second Session
          • Inputs
      • Secretary General's Tax Report 2023
        • Events
        • Inputs
    • Committee of Experts on International Tax Cooperation
      • Committee of Experts on International Tax Cooperation
      • About
        • Nominations for 2025-2029 Term
        • Current Members
        • Recent Members
        • Working Methods
      • Committee sessions
      • Subcommittees
      • Documents
      • Publications
      • Thematic Areas
        • Base Erosion and Profit Shifting
        • Capacity Building
        • Dispute Avoidance and Resolution
        • Environmental Taxation
        • Extractive Industries Taxation
        • Negotiating Bilateral Tax Treaties
        • Tax Consequences of Digitalized Economy
        • Tax, Trade and Investment Treaties
        • Taxation and the SDGs
        • Taxation of Government-to-Government Aid Projects
        • Transfer Pricing
        • UN Model Convention
        • Other
      • Tax Trust Fund
    • ECOSOC Special Meeting on International Cooperation in Tax Matters
    • Tax Cooperation
      • Tax Treaties
      • Tax Base Protection
      • Tax Administration
      • Transfer Pricing
  • Intergovernmental
    • Financing for Development Forum
      • FFD Forum Home
      • About the Forum
      • Registration
      • Past Events
      • Programme
      • Outcomes
      • Side Events
      • Videos
      • Contact
    • Development Cooperation Forum
      • DCF Home
      • 2025 DCF
      • About DCF
      • DCF Survey
      • Outcomes
      • Past Meetings
      • Past Events
      • Policy Analysis
      • Focus Areas
      • Capacity Development
      • Voices
      • Contact
    • High-Level Dialogue on Financing for Development
    • General Assembly 2nd Committee
  • Analysis
    • Financing for Sustainable Development Reports by the IATF on FFD
      • Home
      • About
        • Introduction
        • Inter-agency Task Force members
        • Workstreams
      • Reports
        • 2026 Preparatory Materials
        • 2024 Report
        • 2023 Report
        • 2022 Report
        • 2021 Report
        • 2020 Report
        • 2019 Report
        • 2018 Report
        • 2017 Report
        • Inaugural 2016 Report
      • Themes
        • 2020: Financing sustainable development in an era of transformative digital technologies
        • 2019: Integrated national financing frameworks for sustainable development
        • 2018: Financing investment in selected SDGs
        • 2017: Financing investment and social protection
      • Action Areas
        • Domestic public resources
          • Domestic revenue mobilization and taxation
          • Tax policy effectiveness, transparency and administration
          • Illicit financial flows
          • Return of stolen assets
          • International tax cooperation: International efforts to Combating tax avoidance and evasion
          • International tax cooperation: Combatting money laundering/terrorist financing
          • International tax cooperation: Tax treaties, voluntary agreements and tax incentives
          • International tax cooperation: Capacity building
          • National control mechanisms, transparency, non-discrimination and procurement
          • Fossil fuel subsidies
          • Extractives and resources sector
          • National development banks
          • Subnational urban development/planning, subnational financing
        • Domestic and international private business and finance
          • The investment climate and business environment
          • Achieving financial inclusion
          • Facilitating the flow of remittances
          • Developing domestic capital markets
          • Encouraging quality direct investments
          • Sustainable investing and private sector efforts and initiatives on environmental, social and governance (ESG) factors
          • Encouraging philanthropic engagement that is transparent and accountable
          • Incentivizing investment in underfunded areas, including clean and affordable energy
        • International development cooperation
          • Climate finance, disaster risk and environmental resilience
          • Country allocation, levels of concessionality and graduation issues
          • Development effectiveness
          • Humanitarian finance and peacebuilding
          • Innovative development finance
          • International cooperation and capacity building
          • Multilateral development banks
          • Official development assistance
          • Other official flows and catalysing additional resources
          • Partnerships in education
          • Partnerships in health
          • South-South and triangular cooperation
        • International trade as an engine for development
          • Special and differential treatment/least developed countries
          • Agriculture and fisheries
          • Access to affordable medicines
          • Progress on implementation of the Bali and Nairobi outcomes
          • Trade negotiations, WTO accessions, trade policy reviews and trade monitoring reports
          • Trade and the sustainable development goals
          • Trade Finance
          • Aid for Trade
          • Trade facilitation
          • Development at the local level & the domestic enabling environment for trade
          • Coherence among bilateral and regional trade and investment agreements
          • Trade and investment agreements
          • Gender/women as producers and traders
          • The role of the United Nations Conference on Trade and Development
          • United Nations Commission on International Trade Law
          • Illegal wildlife trade/fishing/logging/mining
        • Debt and debt sustainability
          • Maintaining debt sustainability and improving debt sustainability assessments
          • Improving public debt management
          • Towards responsible borrowing and lending
          • Innovative instruments for managing debt burdens
          • Improving debt data and reporting
          • Debt crisis resolution: Actions by official creditors
          • Additional mechanisms, including involving private creditors
          • Legislative efforts to address non-cooperative minority creditors
          • Strengthening national legislation to address domestic sovereign debt
        • Addressing systemic issues
          • Strengthening global governance
          • Improving cooperation, coordination and policy coherence
          • Enhancing global macroeconomic stability with sustainable development
          • Shaping financial market regulation for sustainable development
          • Promoting safe migration
          • Combating transnational crime
        • Science, technology, innovation and capacity-building
          • Promoting information and communication technology, access to technology for all and social innovation
          • Developing national policy frameworks for science, technology and innovation
          • Creating a more enabling environment for science, technology and innovation
          • National level institutions and mechanisms to strengthen science, technology and innovation
          • International level institutions and mechanisms to strengthen science, technology and innovation
          • Technology transfer
          • Actions within the United Nations or by the United Nations system
          • Capacity building
          • New technologies and financing for development
        • Data, monitoring and follow-up
          • Data availability (including disaggregation), adequacy and standardization
          • Data on cross border financing and domestic resource mobilization
          • Development of specific measures and tools
          • Transparency and needs assessment
          • Efforts to strengthen statistical capacities
        • Cross-cutting issues
          • Delivering social protection and essential public services
          • Ending hunger and malnutrition
          • Closing the infrastructure gap
          • Promoting inclusive and sustainable industrialization
          • Generating full and productive employment for all
          • Protecting ecosystems
          • Promoting peaceful and inclusive societies
          • Gender equality and women's empowerment
          • Investing in children and youth
          • Addressing the diverse needs and challenges faced by countries in special situations
          • Global partnership
      • Data
      • News
    • Secretary General Policy Briefs
    • DESA Policy Briefs
    • DESA Working Paper Series
      • Credit Rating Agencies and Sovereign Debt Paper
  • Engagement
    • SDG Investment Fair
      • SDG Investment Fair Home
      • About the Fair
      • Video Archive
      • Past Events
      • Contact
    • Global Investors for Sustainable Development Alliance
  • Capacity Development
    • Capacity Development Home
      • About Capacity Development
      • Projects
        • Attracting Finance and Investment for the Energy Transition in Africa
      • Workshops
      • DA Project
      • Online courses
      • Publications
      • Tax Talks
    • Financing for Small Island Developing States (FINS)
      • Countries
      • FINS Xchange
      • Support for FINS
      • Videos
      • FINS Resources
    • Infrastructure Asset Management
    • Integrated National Financing Frameworks
  • News
    • Events
  • Documents
    • Key Documents