The Resource Conflicts of attribution of income involving trusts under the OECD Model Convention : the possible impact of the OECD Partnership Report

Conflicts of attribution of income involving trusts under the OECD Model Convention : the possible impact of the OECD Partnership Report

Label
Conflicts of attribution of income involving trusts under the OECD Model Convention : the possible impact of the OECD Partnership Report
Title
Conflicts of attribution of income involving trusts under the OECD Model Convention : the possible impact of the OECD Partnership Report
Creator
Subject
Language
eng
Summary
Discusses conflicts of attribution involving trusts and explores the impact the Partnership Report could have in this area. Illustrates how conflicts of attribution may arise in the field of trusts relationships and demonstrates that the text, the context, as well as the object and purpose of tax treaties patterned upon the OECD Model Convention, dictate that these difficulties be resolved. The authors examine whether, and if so under which conditions, conflicts of attribution involving trusts could be resolved by relying on the general recommendation embodied in the Partnership Report
Citation source
In: Intertax. - The Hague. - Vol. 32 (2004),
http://library.link/vocab/creatorName
Danon, R.J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • allocation of income
  • trust
  • partnership
  • residence
Label
Conflicts of attribution of income involving trusts under the OECD Model Convention : the possible impact of the OECD Partnership Report
Instantiates
Publication
Label
Conflicts of attribution of income involving trusts under the OECD Model Convention : the possible impact of the OECD Partnership Report
Publication

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