The OECD Model Convention and Its Update 2014

Taxation

The OECD Model Convention and Its Update 2014

Edited by Michael Lang · Pasquale Pistone, et al
IBFD Publications BV February 2015

Specifications

ISBN-13
9789087223014
Publisher
IBFD Publications BV
Publication
February 2015
Format
Paperback
Jurisdiction
Netherlands ? Countri(es) for reference only

Details

The OECD published the 2014 Update of the OECD Model Convention in July 2014. The OECD Committee on Fiscal Affairs and its Working Parties have been working on the proposed changes to the OECD Model and the Commentary for some years. The Update in particular addresses issues regarding beneficial ownership, treatment of termination payments, changes to the exchange of information provision and questions arising in the context of emissions permits and credits.

This book includes 11 chapters which analyze the changes made by the Update and assesses their effects on international tax planning. Moreover, the book offers a future outlook of the concept of permanent establishment in the context of the BEPS project. It incorporates the perspective of leading scholars and practitioners dealing with international tax cases.

This book is designed to provide essential insights to academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.

Table of Contents

Preface
List of Authors
Josef Schuch/Erik Pinetz
The Definition of Dividends, Interest, Royalties and Capital Gains
Felipe Vallada
Beneficial Ownership under Articles 10, 11 and 12 of the 2014 OECD Model Convention
Pasquale Pistone/Erich Schaffer
Entertainers According to Art 17 OECD Model Convention
Maryte Somare
Alternative Provisions to Art 17 OECD Model Convention
Claus Staringer/Anna Binder
Students and Business Apprentices According to Art 20 OECD Model Convention
Michael Tumpel/Robert Jahn
Termination of Employment
Edoardo Traversa/Francesco Cannas
Exchange of Information (Art 26 OECD Model Convention)
Michael Wenzl
Tax Treaty Issues Related to Emissions Permits and Credits
Heinz Jirousek
The Implementation of the OECD Update 2014 in Bilateral Tax Treaty Practice – an OECD Member States’ Perspective
Laura Turcan
The OECD Update 2014 and its Impact on the UN Model Convention
Alfred Storck/Alexander Zeiler
Beyond the OECD Update 2014: Changes to the Concepts of Permanent Establishments in the Light of the BEPS Discussion
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