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

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Reproduced at page R(6)-1 of Volume II of the loose-leaf version of the OECD Model Tax Convention. 29 2002 REPORTS RELATED TO THE MODEL TAX CONVENTION noted that any addition to the Commentary had to be drafted in a neutral way so as to avoid inadvertent limitation of the concept. Meaning of beneficial owner 23. The Model Convention does not provide a definition of “beneficial owner”. The Commentary indicates that an intermediary, such as an agent or nominee, is not the beneficial owner, but otherwise does not elaborate on the meaning of the term.

In classifying as royalties payments received as consideration for information concerning industrial, commercial or scientific experience, paragraph 2 alludes to the concept of “know-how”. Various specialist bodies and authors have formulated definitions of know-how which do not differ intrinsically. One such definition, given by the “Association des Bureaux pour la Protection de la Propriété Industrielle” (ANBPPI), states that ‘know-how is all the undivulged technical information, whether capable of being patented or not, that is necessary for the industrial reproduction of a product or process, directly and under the same conditions; inasmuch as it is derived from experience, know-how represents what a manufacturer cannot know from mere examination of the product and mere knowledge of the progress of technique’.

Technical fees Analysis and conclusions 33. The Committee examined how various e-commerce payments would be treated under alternative treaty provisions that allow source taxation of “technical fees”. 34. ” 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.

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