Article 24 (1) of the OECD Model Convention and the exclusion of MFN treatment - a comment on the OECD Public Discussion Draft

Article Abstract:

A Public Discussion Draft was announced to clarify the issue of conflicting provisions in Article 24 of the OECD Model Convention with Double Taxation Conventions of non-EU member states with EU-member states. Suggestions to the changes in the commentary of Article 24 are examined in the context of its effect to the Most Favored Nation Issue.

Administration of General Economic Programs, Most Favored Nation Agreements, Organization for Economic Cooperation and Development, Most favored nation clauses

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Taxation of cross-border savings: options for reviewing the European approach

Article Abstract:

Problem areas and loopholes within the Savings Directive, a directive on the taxation of savings income through interest payments, are discussed. These areas include defining the place of residence of a beneficial owner, treatment of trusts, and classification of income from financial products.

Europe, Taxation, Savings

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