Tax Sparing and Matching Credit: From an Unclear Concept to an Uncertain Regime

Journal
France; International; OECD
Bulletin for International Taxation 2013 (Volume 67), No. 8
This article presents different interpretations of tax sparing and matching credit clauses in tax treaties. In this regard, the article tries to explain how unclear definitions given by the OECD and contradictory theories presented by international scholars have been affecting the applicability of these concepts.