1. Organisation for Economic Cooperation and Development, Treaty Characterisation TAG (Technical Advisory Group on Treaty Characterisation Issues arising from E-Commerce);Tax Treaty Characterisation Issues Arising from E-Commerce Report to Working Party No. 1 of the OECD Committee on Fiscal Affairs,2001
2. Organisation for Economic Cooperation and Development, E-Commerce: Transfer Pricing and Business Profits Taxation;Business Profits TAG (Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits),2001
3. The TAG agreed (ibid, 85) that fairness, and in particular inter-nation equity, was important, but noted that there are no agreed principles of inter-nation equity beyond accepting both residence and source taxation;Some attempt at this was made by the OECD Business Profits TAG (see n 120 above
4. United Nations;Model Double Taxation Convention between Developed and Developing Countries,2001