Treaty Characterization Issues Of Payments On Various E-commerce Transactions

The OECD Committee on Fiscal Affairs (CFA) has undertaken a major consideration of the taxation issues raised by e-commerce and its underlying technologies. The Technical Advisory Groups (TAG) met in September 1999 and in February 2000 and various categories of e-commerce transactions and the treaty characterization issues which arise from these transactions were discussed. However, one of these TAGS was related to the Treaty Characterization of Electronic Commerce Payments, which has received the most attention. TAG’s discussions included a preliminary conclusions and its analysis on 28 different categories of e-commerce transactions. The goal is to “to examine the characterization of various types of electronic commerce payments under tax conventions with a view to providing the necessary clarifications in the Commentary of the OECD Model Tax Convention.”

The following questions have been addressed in this article:

What did the TAG found to be the most controversy issue in characterizing an e-commerce transaction?
Was there a final recommendation on the character of certain e-commerce transaction which was given by TAG?
What categories of transactions were examined in the O.E.C.D. report


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