The effectiveness of the 'place of effective management' tie-breaker rule in the OECD Model Tax Convention / by K. Luker

The effectiveness of the 'place of effective management' tie-breaker rule in the OECD Model Tax Convention / by K. Luker

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Double taxation could arise in a situation where resident- resident conflicts occur. Resident–resident conflicts occur in the situation where both countries regard such a person as a “resident” for tax purposes under their domestic legislation. For that reason, all income that is earned by that pers...

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Bibliographic Details
Main Author: Luker, Karen
Published: North-West University 2011
Subjects:
Article 4
Companies
Double Taxation Agreement
Dual resident
International taxation
OECD Model Convention
Place of central management and control
Place of effective management
Taxation
Tax resident
Tie breaker clause
Online Access:http://hdl.handle.net/10394/4430

Internet

http://hdl.handle.net/10394/4430

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