Add to ORKGThe question whether a dual resident taxpayer is entitled to tax treaties concluded by each residence state with a third state has been controversial. Since 2008, the Organisation for Economic Co-operation and Development (OECD) Commentary on Article 4(1) of the OECD Model states that such a taxpayer would be entitled to only the tax treaty network of residence state as determined by the tiebreaker rule of the tax treaty between the two residence states. While this may be desirable policy, this article examines whether the interpretation espoused by the commentary is legally accurate
Although taxation matters are generally accepted to be an issue of national concern, increasing atte...
This article follows a contribution by the same author, published in the previous edition of the Wor...
The OECD Model Commentary takes the view that treaty residence is defined by comprehensive or full ...
The question whether a dual resident taxpayer is entitled to tax treaties concluded by each residenc...
Case 33872C, which was decided by Luxembourg’s Cour administrative on 18 December 2014, concerned tw...
In order to have access to a tax treaty, it is generally essential that a person qualifies as a resi...
The benefits of a tax treaty are generally granted to persons who are residents of one of the Contra...
This thesis examines whether the fundamental freedoms of the EC Treaty prescribe most-favoured-natio...
This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Co...
This article examines the rather strict interpretation of ´liable to tax´by the Dutch and Canadian S...
Double taxation treaties play a vital part in the international relations between states regarding t...
Bilateral income tax treaties do not always operate effectively in situations where more than two st...
In bilateral tax treaties each self-interested state confers benefits to another State because it ex...
01 Double tax treaties aim to prevent double taxation. Double taxation of income is an undesirable p...
The current tax treaty network was developed in the 1920s and 1930s in order to prevent double resid...
Although taxation matters are generally accepted to be an issue of national concern, increasing atte...
This article follows a contribution by the same author, published in the previous edition of the Wor...
The OECD Model Commentary takes the view that treaty residence is defined by comprehensive or full ...
The question whether a dual resident taxpayer is entitled to tax treaties concluded by each residenc...
Case 33872C, which was decided by Luxembourg’s Cour administrative on 18 December 2014, concerned tw...
In order to have access to a tax treaty, it is generally essential that a person qualifies as a resi...
The benefits of a tax treaty are generally granted to persons who are residents of one of the Contra...
This thesis examines whether the fundamental freedoms of the EC Treaty prescribe most-favoured-natio...
This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Co...
This article examines the rather strict interpretation of ´liable to tax´by the Dutch and Canadian S...
Double taxation treaties play a vital part in the international relations between states regarding t...
Bilateral income tax treaties do not always operate effectively in situations where more than two st...
In bilateral tax treaties each self-interested state confers benefits to another State because it ex...
01 Double tax treaties aim to prevent double taxation. Double taxation of income is an undesirable p...
The current tax treaty network was developed in the 1920s and 1930s in order to prevent double resid...
Although taxation matters are generally accepted to be an issue of national concern, increasing atte...
This article follows a contribution by the same author, published in the previous edition of the Wor...
The OECD Model Commentary takes the view that treaty residence is defined by comprehensive or full ...