Characterization of fictitious income under OECD-patterned tax treaties

Journal
Wattel, P.J.; Marres, O.C.R.
European Taxation 2003 (Volume 43), No. 3
PriceUSD 45

Discussion of circumstances in which fictitious income may fall under the income allocation provisions (Arts. 6-20) of an OECD Model-type tax treaty, the "other income" provision (Art. 21 OECD Model), or outside the scope of the treaty entirely.