The report outlines two main approaches for enforcing of taxation of OITs by the country in which the asset is located—provisions for which require careful drafting. It identifies the two main approaches for so doing and again provides sample simplified legislative language for domestic law in the location country for both. One of these methods treats such an OIT as a deemed disposal of the underlying asset. The other treats the transfer as being...
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The platform for collaboration on tax : Projet soumis à commentaires : L'imposition des transferts indirects opérés à l'étranger – une boîte à outils (French). Platform for Collaboration on Tax Washington, D.C. : World Bank Group. http://documents.worldbank.org/curated/en/387861505311346551