Interest from Hybrid Debts in Tax Treaties

Journal

Author

Pijl, H.

Country

International; OECD; The Netherlands

Published Date

July 15, 2011

Issue

Bulletin for International Taxation 2011 (Volume 65), No. 9

DOI

https://doi.org/10.59403/3sm9apd

Document

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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.

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Interest from Hybrid Debts in Tax Treaties