guidelines can be gathered from the US Model tax convention and the OECD Partnership Report of 1999. Particular anntention in given to the tations of resident
by other enterprises under particular arrangements. Another case would be that of an enterprise which sells tickets on behalf of other companies, for
light of article 24 of the double tax treaty currently in force between Italy and Germany. In particular, it is under exam the possibility to apply, to
"internalista", mientras que la segunda podríadenominarse "sustancial" o "externalista". En particular, defenderé una concepción formal moderada, análoga a
particular on the due process rights aspects of the judgments issued by the General court and the Court of Justice so far. European judges resolutely