Interest from Hybrid Debts in Tax Treaties
Journal
International; OECD; The Netherlands
Bulletin for International Taxation 2011 (Volume 65), No. 9
The author, in this article, examines the interpretation of the treaty terms "interest" and "dividend" with regard to the interaction of articles 10 and 11 of the OECD Model and hybrid debt. In this respect, the author specifically considers the historical background.