The Concept of Debt-Claim as the Key Distinguishing Factor between Dividend and Interest Income in the OECD Model

Type

Journal

Author

Lopes Dias V.S., G.

Country

International

Published Date

February 24, 2015

Issue

Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2015 (Volume 17), No. 2

DOI

https://doi.org/10.59403/wp8dme

Document

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This article thoroughly examines the dividend and interest provisions in Model Conventions as they apply to characterize income from cross-border instruments, considering cases of overlap and thin capitalization.

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The Concept of Debt-Claim as the Key Distinguishing Factor between Dividend and Interest Income in the OECD Model