The Resource Article 19(2) : the complexity of the OECD Model can be reduced

Article 19(2) : the complexity of the OECD Model can be reduced

Label
Article 19(2) : the complexity of the OECD Model can be reduced
Title
Article 19(2) : the complexity of the OECD Model can be reduced
Creator
Subject
Language
eng
Summary
The OECD Model Tax Convention contains a complex system for allocating taxing rights between the residence state and the source state. Technically, it would be possible to reduce the number of rules dramatically, but the acceptance of the OECD Model depends to a certain extent on some complexity. The disadvantages of a complex system for allocating taxing rights, however, are evident. The tax treatment of pensions in the OECD Model is an example of such complexity. This article examines the various provisions of the OECD Model which affect the tax treatment of pensions - in particular Art. 19 and its relation to other provisions of the OECD Model. The article concludes that Art. 19 is the cause of many difficulties concerning how to draw the borderline between Art. 19 and the other provisions. One possible solution would be to delete Art. 19 or at least Art. 19(2)
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 61 (2007),
http://library.link/vocab/creatorName
Lang, M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD Model
  • allocation of taxing rights
  • pension
Label
Article 19(2) : the complexity of the OECD Model can be reduced
Instantiates
Publication
Label
Article 19(2) : the complexity of the OECD Model can be reduced
Publication

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