This course begins with a discussion of the general aspects of the OECD Model Double Taxation Convention. Next, the treaty attribution rules are analysed.
This course begins with a discussion of the general aspects of the OECD Model Double Taxation Convention (policy, background and development), of the scope of the Model and the general definitions it employs, and of tax treaty interpretation. Next, the treaty attribution rules are analysed with regard to business and professional income (Art. 7), transportation income (Art. 8), real property income (Art. 6), dividends (Art. 10), interest (Art. 11), royalties (Art. 12) and capital gains (Art. 13). Subsequently, after the intermediate exam, attention is focused on the treaty attribution rules with respect to services, including employment and pension income (Art. 15 through 20), other income (Art. 21) capital (Art. 22) and double taxation relief (Art. 23A-B). The course is concluded by discussions of the technically complex subjects such as e-commerce, beneficial ownership & international tax avoidance, partnerships, triangular cases, financial instruments and international trade dispute resolution in tax matters and by a detailed discussion of tax treaty policy issues. Teaching is offered in different forms.