The relevance of the commentaries on the OECD and UN models for the interpretation of the UN model /David Orzechowski --Business profits, permanent establishments and associated enterprises /Raffaele Petruzzi and Viktoria Wöhrer --Independent and dependent personal services /Benjamin Walker and...

Legal fictions have been included in various tax laws in many countries. In respect of tax treaties, they may give rise to various questions, such as:• Does the inclusion of a legal fiction in a national tax law after the conclusion of a tax treaty constitute tax treaty override?• Does the...