Add to ORKGThe benefits of a tax treaty are generally granted to persons who are residents of one of the Contracting States. The determination of such tax residence status is, however, not always an easy task and is particularly problematic in relation to entities whose tax characterisation differs from one Contracting State to another thereby giving rise to conflicts of allocation of income. As a remedy for this, the OECD has introduced a new Article 1(2) in to the OECD Model Tax Convention 2017 (the OECD Model), the text of which is also replicated in Article 3(1) of the Multilateral Instrument (MLI). This provision, which reproduces the principles already settled within the 1999 OECD Partnership Report and which uses a wording which mirrors Article...
The discussion regarding the interaction between Article 6 (Income from Immovable Property), Article...
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3...
In order to have access to a tax treaty, it is generally essential that a person qualifies as a resi...
The international tax debate as regards hybrid entities has certainly changed after the OECD BEPS Pr...
Article 21 of the OECD Model Tax Convention on Income and on Capital has seldom captured the attenti...
This article argues that despite its apparent success as a political instrument to achieve global co...
This article follows a contribution by the same author, published in the previous edition of the Wor...
This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Co...
The subject of the article. The article represents a research of conceptual properties and issues of...
The question whether a dual resident taxpayer is entitled to tax treaties concluded by each residenc...
Although taxation matters are generally accepted to be an issue of national concern, increasing atte...
In this article, the authors consider some of the practical issues relating to the introduction of t...
01 Double tax treaties aim to prevent double taxation. Double taxation of income is an undesirable p...
This article argues that the “saving clause” provision introduced in the 2017 OECD Model conflicts w...
This article sets out some reflections of the authors on those aspects of the OECD’s October 2015 fi...
The discussion regarding the interaction between Article 6 (Income from Immovable Property), Article...
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3...
In order to have access to a tax treaty, it is generally essential that a person qualifies as a resi...
The international tax debate as regards hybrid entities has certainly changed after the OECD BEPS Pr...
Article 21 of the OECD Model Tax Convention on Income and on Capital has seldom captured the attenti...
This article argues that despite its apparent success as a political instrument to achieve global co...
This article follows a contribution by the same author, published in the previous edition of the Wor...
This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Co...
The subject of the article. The article represents a research of conceptual properties and issues of...
The question whether a dual resident taxpayer is entitled to tax treaties concluded by each residenc...
Although taxation matters are generally accepted to be an issue of national concern, increasing atte...
In this article, the authors consider some of the practical issues relating to the introduction of t...
01 Double tax treaties aim to prevent double taxation. Double taxation of income is an undesirable p...
This article argues that the “saving clause” provision introduced in the 2017 OECD Model conflicts w...
This article sets out some reflections of the authors on those aspects of the OECD’s October 2015 fi...
The discussion regarding the interaction between Article 6 (Income from Immovable Property), Article...
This article will proceed as follows. Section 2 summarizes the main provisions of the MLI. Section 3...
In order to have access to a tax treaty, it is generally essential that a person qualifies as a resi...