Processing...
Continue shopping Go to cart
return to product list

Article 16 of the OECD Model Convention: History, Scope and Future

This book combines an in-depth analysis of the scope of application and the legal consequences of Article 16 with suggestions for rethinking the provision.

 

tab_0
Title:

Article 16 of the OECD Model Convention: History, Scope and Future

Series:

Volume 1 in the WU Series

Author(s):
Date of publication:
ISBN:

978-90-8722-319-9

Type of publication:

Print book

Number of pages:

352

Terms:

Shipping fees apply. View shipping information

Price:
EUR 105 / USD 125 (VAT excl.)
Order Print
tab_1
Title:

Article 16 of the OECD Model Convention: History, Scope and Future

Series:

Volume 1 in the WU Series

Author(s):
Date of publication:
ISBN:

978-90-8722-320-5

Type of publication:

eBook in ePub format

Number of pages:

352

Other:

Please note: Adobe Digital Editions is required

Read our eBook FAQ | Download sample

Price:
EUR 84 / USD 100 (VAT excl.)
Order eBook: ePub
tab_2
Title:

Article 16 of the OECD Model Convention: History, Scope and Future

Series:

Volume 1 in the WU Series

Author(s):
Date of publication:
ISBN:

978-90-8722-319-9

Type of publication:

Online book

Number of pages:

352

Access:

Up to 5 users. View purchase information.

Price:
EUR 105 / USD 125 (VAT excl.)
Order Online Book
tab_offer
  • Order both the print and an electronic version of the book and receive a 20% discount on each format. The discount is calculated automatically in your shopping cart.
  • Bulk discounts apply on orders of 11 or more books of the same format (this applies to each of the formats). The offer is not valid for resellers.
  • Students are entitled to a 50% discount on IBFD books (valid student card required).

To obtain bulk or student discounts, contact Customer Support.

Article 16 of the OECD Model Convention: History, Scope and Future

Why this book?

Article 16 is one of the few provisions of the OECD Model that have remained virtually the same since the Model was first published in 1963 and consists of only one sentence: “Directors’ fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State.” OECD member countries as well as a considerable number of non-members accept Article 16 of the Model as a guideline for their bilateral treaty negotiations, often following it to the letter.

Nevertheless, the scope of this provision is still vague in many respects. Therefore, this book provides evidence on the interpretation and the legal effects of Article 16 by way of answering the following questions: Who might be a director? What activities are performed by a director? Under what conditions is a company resident in the other contracting state? Which company organs are comprised? What conditions exist for being a member of a board of directors? How to draw a line between Article 16 and other distribution rules for certain types of remuneration. What is the relation between Article 16 and domestic law provisions? How likely is it that double or non-taxation arises in triangular situations?

The last part of the book approaches Article 16 from a tax policy point of view. It analyses why Article 16 fulfils an important role within the OECD Model and provides modifications in order to compensate current shortcomings of the provision.
 

Downloads

 

Author(s)

Dr Elisabeth Pamperl currently works in the tax department of Deloitte Vienna and is author of various publications in international and domestic Austrian tax law. This book is based on her doctoral thesis, which she wrote while being a research and teaching associate at the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business (WU).

 

return to product list