ACO Case Study - Model Tax Convention - Tax Law Assignment Help

Assignment Task :

Question 1 n

ACO, a company resident in country A, carries on a video streamingbusiness. In return for monthly subscription fees, customers are able to watchvideos online, and are able to download copies of videos on to their mobiledevices in order to watch the videos offline (for a limited period).

ACO is the owner or licensee of the copyright in its library of videos. ACO hasmany individual customers in country B. These individual customers enter intosubscription contracts with ACO on ACO's website. Monthly subscriptionpayments are made to ACO by the charging of customers' credit cards(evidenced by invoices which ACO sends to customers' email addresses).

ACO has no physical presence in country B. However, ACO is registered forgoods and services tax (known as VAT) in country B, and has appointed anunrelated accounting firm (BCO) in country B to act as its VAT agent.

In accordance with country B law, ACO charges VAT on its invoices tocountry B customers. Country A and Country B have concluded a double taxtreaty in identical terms to the 2017 OECD Model Tax Convention (MTC).

Required: 

Discuss whether country B is allowed to tax the income receivedby ACO from its customers in country B under the A/B treaty?

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