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International - The Concept of Debt-Claim as the Key Distinguishing Factor between Dividend and Interest Income in the OECD Model

Country:
International
Author:
G. Lopes Dias V.S.
Issue:
Derivatives & Financial Instruments, 2015 (Volume 17), No 2
Published:
24 February 2015
This article thoroughly examines the dividend and interest provisions in Model Conventions as they apply to characterize income from cross-border instruments, considering cases of overlap and thin capitalization.
 
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