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Understanding the OECD Model of Tax Convention: The Lesson of History
Florida Tax Review, 2022An important recent development in international taxation is the publication of the OEEC (the forerunner of the OECD when it was a purely European organization, although representatives from the United States and Canada were also present at the discussions on tax treaties) archives on the development of tax treaties in a website http://www ...
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The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties
2012This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions from five continents and empirically ascertains the impact of the UN and OECD Model Tax Conventions on bilateral tax treaties. It therefore fills a major gap in the international tax literature, which has so far either studied the sole Model Tax Conventions
Burgers, I.J.J. +2 more
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The Impact of the UN and OECD Model Tax Conventions on Turkish Tax Treaties
Intertax, 2011Turkey is an appealing country for global investors. The economical importance of Turkey with the defragment of the geopolitical importance will gain deeper dimension and meaning. Since the outbreak of the global financial system crisis, the issue of tax cooperation between related parties has a priority on the international agenda.
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Taxes on Income According to Article 2(1) and (2) OECD Model Convention 2017
SSRN Electronic Journal, 2020The paper forms part of the book compiling papers presented at the MaiSymposium at WU in 2020. The paper discusses the meaning and scope of various terms in Article 2(1) and 2(2) of OECD MC, 2017 with a focus on taxes on income. The paper undertakes a historical analysis of various deliberations that led to the framing of Article 2(1) and 2(2) to ...
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Asia-Pacific Tax Bulletin, 2009
This author, further to an earlier article introducing the UN Model Convention and the nature and work programme of the UN, details the main differences with the OECD Model Convention and the reason for the differences.
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This author, further to an earlier article introducing the UN Model Convention and the nature and work programme of the UN, details the main differences with the OECD Model Convention and the reason for the differences.
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Income from inactivity under Article 15 of the OECD Model Tax Convention : Part 1
Bulletin for International Taxation, 2009In this two-part article, the author first introduces the topic of the taxation of income from inactivity under Art. 15 of the OECD Model Tax Convention. He then considers, in Part 1, compensation for the cancellation of employment, sickness benefits and disability allowances and income derived from non-competition agreements.
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An Introduction to the 2010 Update of the OECD Model Tax Convention
Bulletin for International Taxation, 2010In this short introduction to the 2010 Update to the OECD Model Tax Convention, the author gives his views and opinions on some of the changes made to Art. 7, its Commentary and the Commentaries in general.
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The Dual System of OECD Model Tax Conventions from the Evolutionary Perspective
Intertax, 2018This article attempts to analyse, from the evolutionary perspective, the dual system of OECD Model Tax Conventions that arguably came into existence as a result of a tax policy choice that was introduced from the very beginning of works on bilateral model solutions concerning the elimination of international juridical double taxation.
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Article 26 of the OECD Model Tax Convention on Income and on Capital
2016This chapter explains Article 26 of the OECD Model Tax Convention on Income and on Capital. Canada has over ninety double tax conventions (DTCs) in force that contain an article modelled on Article 26, and the United States has over sixty. As explained in Chapter 6, both Canada and the United States generally reserve the use of DTCs for countries with ...
David S. Kerzner, David W. Chodikoff
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The United Nations Model and OECD Model Tax Conventions
2022Lorenzo Riccardi, Giorgio Riccardi
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