Source Versus Residence
Author(s)
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Publisher
ISBN
9788171944989
Edition
2008 Edition
Pages | Format
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Approx. Product Size
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Note : The OECD Model Tax Convention, other treaties, and the bilateral treaties drafted in accordance with these models allocate the taxing rights between the state of source and the state of residence
Description
The allocation rules for income taxation are determined by Articles 6 to 21 of the OECD Model Convention. Courts, tax administrations, and practitioners have to deal with a growing number of interpretation and application problems in connection with these rules. The publication at hand provides an analysis of the allocation rules of the OECD Model Tax Convention and their equivalents in bilateral tax treaties and proposes possible alternatives.
