The new approach to qualification conflicts has its limits

Journal
Rust, A.
Bulletin for International Taxation 2003 (Volume 57), No. 2
FormatPDF
EUR
40
| USD
45
(VAT excl.)

This article continues Prof. Vogel's examination on the new interpretation of Art. 23 of the OECD Model Tax Convention. The author focuses on the relationship between "complete" distributive rules and Art. 23 and shows that, in some cases of negative qualification conflicts resulting in double non-taxation, the new approach does not have any impact.