Exemption Method and Credit Method
Special offer
- Order the print together with any electronic format of the same title and receive a 20% discount on each format. The discount is calculated automatically in your shopping cart.
- Bulk discounts apply on orders of 10 or more books of the same format (this applies to each of the formats) with a maximum of 20% discount. The offer is not valid for resellers.
- Students are entitled to a 50% discount on IBFD books and 20% discount on third party books (valid student card required).
To obtain student discounts, contact Customer Support.
Online books
Access your online books on the Tax Research Platform.
Don’t have a Tax Research Platform subscription?
Learn more
This book aims to provide an in-depth analysis of any and all current issues related to the application of Art 23A and 23B of the OECD Model.
Why This Book?
The method article of any tax treaty plays an essential role in avoiding juridical double taxation. It determines the extent to which the residence state refrains from taxing an item of income if both contracting states may tax according to the distributive rules of the treaty. Calculating the respective relief can be challenging, as the wording of both articles 23A and 23B of the OECD Model leaves significant room for interpretation. In the European Union, such interpretation is made even more difficult because the application of the method article needs to comply with EU law, in particular with the fundamental freedoms and the State aid rules. Finally, the method article of the OECD Model has – in the aftermath of the Base Erosion and Profit Shifting Project – undergone adaptations, the impact of which requires further analysis.
This book aims to provide an in-depth analysis of all the current issues related to the application of articles 23A and 23B of the OECD Model. The topics discussed include:
- the method article and unilateral measures to avoid double taxation;
- the method article and allocation conflicts;
- conflicts of qualification under articles 23A(1) and 23B(1) of the OECD Model;
- the credit method and different taxes on income and on capital;
- the exemption method with proviso safeguarding progression; and
- relief from double taxation and EU State aid law
Exemption Method and Credit Method
DOI: https://doi.org/10.59403/3cbfx2z
Go to Tax Research Platform
Chapter 1: Method Article and Unilateral Measures to Avoid Double Taxation
DOI: https://doi.org/10.59403/3cbfx2z001
Go to Tax Research Platform
Chapter 2: Method Article and Allocation Conflicts
DOI: https://doi.org/10.59403/3cbfx2z002
Go to Tax Research Platform
Chapter 3: Conflicts of Qualification under Articles 23A(1) and 23B(1)
DOI: https://doi.org/10.59403/3cbfx2z003
Go to Tax Research Platform
Chapter 4: Conflicts of Qualification under Article 23A(4)
DOI: https://doi.org/10.59403/3cbfx2z004
Go to Tax Research Platform
Chapter 5: Notion of “Tax” under the Credit Method
DOI: https://doi.org/10.59403/3cbfx2z005
Go to Tax Research Platform
Chapter 6: Credit Method and Maximum Tax Credit
DOI: https://doi.org/10.59403/3cbfx2z006
Go to Tax Research Platform
Chapter 7: Credit Method and Different Taxes on Income and on Capital
DOI: https://doi.org/10.59403/3cbfx2z007
Go to Tax Research Platform
Chapter 8: Tax Sparing
DOI: https://doi.org/10.59403/3cbfx2z008
Go to Tax Research Platform
Chapter 9: Exemption Method with Proviso Safeguarding Progression
DOI: https://doi.org/10.59403/3cbfx2z009
Go to Tax Research Platform
Chapter 10: Exemption Method and Domestic Law
DOI: https://doi.org/10.59403/3cbfx2z010
Go to Tax Research Platform
Chapter 11: Method Article, Secondary EU Legislation and the Fundamental Freedoms
DOI: https://doi.org/10.59403/3cbfx2z011
Go to Tax Research Platform
Chapter 12: Relief from Double Taxation and EU State Aid Law
DOI: https://doi.org/10.59403/3cbfx2z012
Go to Tax Research Platform
G. Kofler et al.
François Barreau, Valentin Bendlinger, Vera Hellebrandt, Rita Julien, Georg Kofler, Michael Lang, Belisa Ferreira Lotti, Xiangdan Luo, Joy Waruguru Ndubai, Theres Neumüller, Nicholas Pacher, Cristian Camilo Rodriguez Peña, Pasquale Pistone, Siddhesh Rao, Alexander Rust, Philipp Walter Scharizer, Karoline Spies, Claus Staringer
