Income from Inactivity under Article 15 of the OECD Model Tax Convention – Part 2

In Part 2 of this article, the author continues the examination of the topic of the taxation of income from inactivity under Art. 15 of the OECD Model Tax Convention by considering stand-by fees, severance payments and sign-on fees. Compensation for the cancellation of an employment, sickness benefits and disability allowances and income derived from non-competition agreements were dealt with in Part 1, which was published in the October 2009 issue of the Bulletin for International Taxation.