The Resource The definitions of dividends and interest contained in the OECD Model, actual tax treaties, and the German Model

The definitions of dividends and interest contained in the OECD Model, actual tax treaties, and the German Model

Label
The definitions of dividends and interest contained in the OECD Model, actual tax treaties, and the German Model
Title
The definitions of dividends and interest contained in the OECD Model, actual tax treaties, and the German Model
Creator
Subject
Language
eng
Summary
Tax treaties distinguish between dividends and interest, and entitle recipients of this remuneration derived from financial instruments to different treaty benefits in the source country in particular. Hence, the definitions of dividends and interest for tax treaty purposes are decisive. This article presents and compares these definitions contained in the OECD Model and the tax treaties agreed by Australia, Brazil, Germany, Italy, and the Netherlands. It offers an analysis of the definitions of dividends and interest outlined in the German Model and reveals that legal certainty is not fully achieved. Moreover, the German Model does not comprehensively prevent the effect of hybrid mismatch arrangements
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 42 (2014),
http://library.link/vocab/creatorName
Bärsch, S-E
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • OECD Model
  • dividend
  • interest
  • tax treaty
  • financial instrument
  • income classification
  • tie-breaker rule
Label
The definitions of dividends and interest contained in the OECD Model, actual tax treaties, and the German Model
Instantiates
Publication
Label
The definitions of dividends and interest contained in the OECD Model, actual tax treaties, and the German Model
Publication

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