The Resource An argument for treating distributions by Austrian private foundations to foreign beneficiaries as dividends under tax treaties based on the OECD Model

An argument for treating distributions by Austrian private foundations to foreign beneficiaries as dividends under tax treaties based on the OECD Model

Label
An argument for treating distributions by Austrian private foundations to foreign beneficiaries as dividends under tax treaties based on the OECD Model
Title
An argument for treating distributions by Austrian private foundations to foreign beneficiaries as dividends under tax treaties based on the OECD Model
Creator
Subject
Language
eng
Summary
This article presents an argument that distributions paid by Austrian private foundations to foreign beneficiaries should be treated as dividends rather than as other income under Austrian tax treaties that are based on the OECD Model
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 74 (2020), no. 8 ; p. 481-486
http://library.link/vocab/creatorName
Bergmann, S
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • tax treaty
  • OECD Model
  • income classification
  • dividend
  • other income
  • private foundation
  • domestic tax law
Label
An argument for treating distributions by Austrian private foundations to foreign beneficiaries as dividends under tax treaties based on the OECD Model
Instantiates
Publication
Label
An argument for treating distributions by Austrian private foundations to foreign beneficiaries as dividends under tax treaties based on the OECD Model
Publication

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