This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. These changes and their implementation warrant an assessment of their desirability, including an in-depth...

This article analyses the meaning of the definitions of dividend and interest in the OECD Model by reference to their historical evolution. In the dividend definition the origin of 'other corporate rights' is traced to a 1958 OEEC Working Party minute in which the same French expression used in...

This contribution deals with the question whether - from the perspective of cross-border neutrality - tax reductions for personal circumstances should be applied only by the country of residence, or whether they should also be granted by the source country, and, if so, how such tax reductions...

This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. These changes and their implementation warrant an assessment of their desirability, including an in-depth...

This material was first published by Sweet & Maxwell Limited in Angelo Nikolakakis, Stephane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Johann Hattingh, Koichi Inoue, Juergen Luedicke, Guglielmo Maisto, Toshio Miyatake, Kees van Raad, Richard Vann and...

The chapter concerns limitations of bilateral tax treaties in multilateral situations (triangular cases). Such limitations result from the bilateral nature of tax treaties. Tax treaties based on the OECD Model or the UN Model are concluded by two parties, aiming to resolve juridical double...