2008 OECD Model : conflicts of qualification and double non-taxation

Michael Lang

21 citations0/0 files storedBulletin for international taxation

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Taxation and Legal Issues Economic and Fiscal Studies Corporate Taxation and Avoidance

Abstract

The 2008 Update of the OECD Model modified Para. 32.6 of the Commentary on Art. 23 (Elimination of double taxation). Para. 32.6 was added in 2000 and deals with double non-taxation arising from conflicts of qualification. The changes to Para. 32.6, although minor, deserve careful analysis because the issue of qualification conflicts resulting in double non-taxation is highly controversial. This article examines the changes to Para 32.6 and analyses the policy and legal considerations relating to the approach taken in Para. 32.6.

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2019The True Nature of Tax Treaties 2020Tax Treaty Interpretation – A Response to John Avery Jones 2010The Object of Art. 9(1) of the OECD Model Convention: Commercial or Financial Relations

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