A Comparative Analysis of Article 10(5) of the OECD Model as Implemented in Tax Treaties and Relevant Case Law

Journal
De Santis, D.A.
OECD
Bulletin for International Taxation 2013 (Volume 67), No. 4/5
PriceUSD 45

This article provides a comprehensive analysis of issues arising from the interpretation of article 10(5) of the OECD Model which prohibits the extraterritorial taxation of dividends or profits, and analyses whether or not the range of existing tax treaties that are in force assist in this process.