International - The Concept of Debt-Claim as the Key Distinguishing Factor between Dividend and Interest Income in the OECD Model
- G. Lopes Dias V.S.
- Derivatives & Financial Instruments, 2015 (Volume 17), No 2
- 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.