July 2014  
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Issue No. 2 - 2014 of the World Tax Journal is now available online.

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Number 2 - 2014 contains the following:
Tax Treaty Treatment of Dividend Related Payments under Share Loan Agreements
Katja Dyppel Weber
The article analyses some of the qualification and allocation challenges that dividend related payments under share loan agreements give rise to for tax treaty purposes. The analysis is based on constructed scenarios illustrating how inconsistent domestic allocation of the dividend related payments give rise to qualification and allocation conflicts for tax treaty purposes in cross-border situations. The main challenges concern to what extent dividend related payments may be covered by the term “dividends” in article 10 of the OECD double tax convention and to what extent the lender in a share loan agreement fulfils the beneficial ownership requirement.
Attribution of Functions and Profits to a Dependent Agent PE: Different Arm’s Length Principles under Articles 7(2) and 9?
Kasper Dziurdź
This article argues that under the OECD Model, conceptually, there should be no difference between the arm’s length principles of articles 7(2) and 9, and analyses how control functions as significant people functions can still lead to a net profit attribution to a dependent agent PE above zero.
Tax Incentives, Tax Expenditures Theories in R&D: The Case of Sweden
Åsa Hansson and Cécile Brokelind
This article investigates whether public funds should support R&D and if so, how such support should be designed in order to be efficient and to comply with the legal requirements stated in EU law and in domestic budget law. The article puts the emphasis on tax expenditure and, in particular, on tax incentives. The findings show that Member States should only subsidize projects where the social benefit exceeds the private benefit. However, in reality, such selection proves impossible, and even if it was possible, EU State aid law could prohibit it.
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