Tax treaty issues relating to cross-border employee stock options

Summary of the discussion at the joint IFA/OECD seminar (Seminer F: The OECD Model Convention - 2002 and beyond) at the 2002 IFA congress in Oslo on treaty issues relating to cross-border employee stock options. After the introductory remarks, four cases are considered: source taxation of stock options, services to which the option relates, change in residence between the grant and the exercise of the option, and exemption method.