Number 1 - 2007 contains the following:
 

This article examines the theory, history and operation of the question of "source of income" from the perspective of the taxation of intellectual property rights and of supplies of substantial intellectual content under tax treaties and its implications and possible evolution in the e-commerce context and the digital age. Specifically, the article discusses the theory of source taxation of intellectual property; intellectual supplies and tax treaties; and towards a coherent framework for the taxation of intellectual supplies in tax treaties. The article concludes that, although reform is presently premature, a new framework for taxing intellectual supplies will be required, and the article proposes a new framework for doing so.

The OECD Model Tax Convention contains a complex system for allocating taxing rights between the residence state and the source state. The disadvantages of a complex system for allocating taxing rights are evident. The tax treatment of pensions in the OECD Model is an example of such complexity. This article examines the various provisions of the OECD Model which affect the tax treatment of pensions - in particular Art. 19 and its relation to other provisions of the OECD Model. The article concludes that Art. 19 is the cause of many difficulties concerning how to draw the borderline between Art. 19 and the other provisions. One possible solution would be to delete Art. 19 or at least Art. 19(2).

The Nordic countries - Denmark, Finland, Iceland, Norway and Sweden - concluded a multilateral convention for the avoidance of double taxation with respect to taxes on income and on capital in 1996. It entered into force in 1997 and became effective on 1 January 1998. The Nordic Convention is based on the OECD Model Tax Convention on Income and on Capital, but adapted for a multilateral format. There are also some substantial differences. This is the first article in a three-part series on the Nordic Convention. This article discusses the general scope of the Convention, looks at the general definitions in it, and considers the interpretation of the Convention. The other two articles will discuss other aspects of the Nordic Convention and will be published in forthcoming issues of the Bulletin.