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Somewhat more specifically, the commentary to Article 5(4) OECD MTC states that “it…
In our view, a holistic assessment of the more detailed examples given in the commentary…
A notable exception to the aforementioned low requirements for surpassing the “auxiliary…
In case a PE is assumed, the profit allocation follows the standard approach. If…
A particular problem would arise if systematic data gathering gave rise to a PE,…
