An Argument for Treating Distributions by Austrian Private Foundations to Foreign Beneficiaries as Dividends under Tax Treaties Based on the OECD Model
Journal
Austria; OECD
Bulletin for International Taxation 2020 (Volume 74), No. 8
This article presents an argument that distributions paid by Austrian private foundations to foreign beneficiaries should be treated as dividends rather than as other income under Austrian tax treaties that are based on the OECD Model.