Recent Developments and Challenges Regarding Exit Taxes in the Context of Tax Treaties: Article 13 of the OECD Model and Change of Residence

Journal
Moser, K. (Karen)
International; OECD; South Africa
Bulletin for International Taxation 2019 (Volume 73), No. 10
FormatPDF
EUR
40
| USD
45
(VAT excl.)

In this article, the author considers whether article 13(5) of the OECD Model applies to exit taxes and whether it precludes the application of exit taxes. The author also examines to what extent tax treaties can mitigate the risk of double taxation with regard to exit taxes.