Why this book?
This study considers the treatment of income from private employment under tax treaties containing provisions analogous or similar to Article 15 of the OECD Model. It offers an in-depth analysis of these provisions as well as suggestions for improvements in the application and interpretation.
It approaches the analysis of Article 15 of the OECD Model from the perspective of five key countries: Belgium, Germany, the Netherlands, the United Kingdom and the United States. By analysing case law, legal literature and official policy statements of these countries' respective tax authorities, the study also describes potential difficulties.
An overview is provided of the various interpretations and explanations employed in these countries, which is also used by the author in developing a preferred interpretation of a term at issue.
This book is part of the IBFD Doctoral Series
Frank Pötgens is a tax lawyer practising at De Brauw Blackstone Westbroek, Amsterdam, the Netherlands and teaches International Tax Law at the Erasmus University of Rotterdam.