Cross-border taxation of employee stock options : how to improve the OECD Commentary - Part 1
Journal
European Taxation 2007 (Volume 47), No. 8
In this first of a two-part article, the authors discuss if, and when, employee stock option benefits should be taxed as employment income (Art. 15 of the OECD Model) or as capital gains (Art. 13 of the OECD Model).