Defining the objective scope of income tax treaties : the impact of other treaties and EC law on the concept of tax in the OECD Model

Resource Information

The work Defining the objective scope of income tax treaties : the impact of other treaties and EC law on the concept of tax in the OECD Model represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Defining the objective scope of income tax treaties : the impact of other treaties and EC law on the concept of tax in the OECD Model

Creator

• Martín Jiménez, A.J

Subject

• inheritance tax
• gift tax
• social security
• OECD Model

Language

eng

Summary

This study deals with some specific problems of Art. 2 (Taxes covered) of the OECD Model Tax Convention, but is not limited to that article. The word "tax" is used not only in Art. 2, but also in the "administrative provisions", in particular, Arts. 24, 26 and 27 of the OECD Model. This study first examines two specific problems regarding Art. 2: whether social security contributions are covered by Art. 2, and the sometimes difficult interaction of Art. 2 with the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts. The study then considers the meaning of the word "tax" in Arts. 24, 26 and 27. The choice of issues to be studied is largely determined by other international norms which may have an impact on these articles of the OECD Model. The author's conclusion on the objective scope of income tax treaties, however, is of a general nature

Citation source

In: Bulletin for international fiscal documentation. - Amsterdam. - Vol. 59 (2005),

Geographic coverage

International

Language note

English