Article 24 (1) of the OECD Model Convention and the exclusion of MFN treatment - a comment on the OECD Public Discussion Draft
Article Abstract:
A Public Discussion Draft was announced to clarify the issue of conflicting provisions in Article 24 of the OECD Model Convention with Double Taxation Conventions of non-EU member states with EU-member states. Suggestions to the changes in the commentary of Article 24 are examined in the context of its effect to the Most Favored Nation Issue.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
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Taxation of cross-border savings: options for reviewing the European approach
Article Abstract:
Problem areas and loopholes within the Savings Directive, a directive on the taxation of savings income through interest payments, are discussed. These areas include defining the place of residence of a beneficial owner, treatment of trusts, and classification of income from financial products.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
User Contributions:
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