НЯКОИ РАЗЛИЧИЯ В ПОНЯТИЕТО ЗА МЯСТОТО НА СТОПАНСКА ДЕЙНОСТ В МОИСР И МООН
SOME DIFFERENCES IN THE CONCEPT OF PERMANENT ESTABLISHMENT IN THE OECD-MC AND UN-MC

Summary/Abstract: The term permanent establishment plays an important role in the international taxation. It is introduced in Art. 5 of the OECD Model Tax Convention on Income and on Capital and of the United Nations Model Double Taxation Convention between Developed and Developing Countries. At first glance the two models may be defined as similar in this regard, but there are some differences therein upon careful reading. The purpose of this article is to examine these differences both from theoretical and practical perspective, paying attention to the latest English versions of both models from 2017. This helps to outline the legal nature of the permanent establishment, as well as to determine to what extent it meets the current international trade trends.

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