id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-351	Avery Jones, CBE, John F.	Understanding the OECD Model of Tax Convention: The Lesson of History	2022	50	.pdf	application/pdf	20540	794	52	As the residence article was one of the first set of articles to be completed, along with permanent establishment, taxes covered and non- discrimination, the relationship with other articles was never explored. They said that profits arising on the alienation of the enterprise should be considered in connection with capital gains.107 Letting of a permanent establishment gave rise to different views: that it was possible that the permanent establishment ceased to exist when let, and that this was a management arrangement rather than a letting.108 In the end the definition of profits was dropped in favour of a priority rule that originally referred to seven other articles having priority and eventually ended with the current reference to items of income dealt with by other articles generally.	cache/ftr-351.pdf	txt/ftr-351.txt