(1) In this section -
'Article 7 of the OECD Model Tax Convention' means the provisions contained in Article 7 of the Model Tax Convention on Income and on Capital published by the OECD on 21 November 2017;
'authorised OECD approach guidance' means the guidance on the attribution of profits to permanent establishments set out in the 2010 Report on the Attribution of Profits to Permanent Establishments approved for publication by the Council of the OECD on 22 July 2010, supplemented by the whole or part of such additional guidance on the attribution of profits to permanent establishments, published by the OECD on or after the date of the passing of the Finance Act 2021, as may be designated by the Minister for Finance for the purposes of this section by order made under subsection (5);
'branch', in relation to a company which is not resident in the State, means a branch or agency through which the company carries on a trade in the State;
'double taxation relief arrangements' means arran
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