The Application of the OECD Model Tax Convention to Partnerships
The application of tax treaties to cases involving partnerships raises a number of complex issues. When is a partnership entitled to the benefits of a tax convention? What happens when the residence and source States apply different articles of the Convention on the basis of differences in their dom...
| Main Author: | |
|---|---|
| Corporate Authors: | , , |
| Format: | eBook |
| Language: | Inglés |
| Published: |
Paris :
OECD Publishing
1999.
|
| Series: | Issues in International Taxation,
no.6. |
| Subjects: | |
| See on Biblioteca Universitat Ramon Llull: | https://discovery.url.edu/permalink/34CSUC_URL/1im36ta/alma991009705082406719 |
Table of Contents:
- I. Introduction
- I.1 Background
- I.2 Organization of the Report
- II. Application of Tax Conventions by the State of Source
- -II.1 Preliminary Remarks on the Tax Treatment of Foreign Entities
- II.2 Differences that Affect the Tax Treatment of Partnerships
- II.3 When is a Partnership Entitled to the Benefits of a Tax Convention?
- II.4 The Partners' Entitlement to Treaty Benefits when the Partnership is Not a Resident
- II.5 Entitlement to Treaty Benefits when one State Treats the Partnership as a Taxable Entity
- II.6 Application of the Convention where the Benefits are Dependent upon Certain Characteristics or Attributes of the Taxpayer
- III. Applicaton of Tax Conventions by the State of Residence
- -III.1 Conflicts of Qualification
- III.2 Problems Arising form Conflicts of Income Affiliation
- Annex I. Proposed Changes to the OECD Model Tax Convention
- Articles of the Model
- Commentary
- Annex II: Reservations
- France
- Germany
- The Netherlands
- Portugal
- Switzerland
- Appendix III: List of Entities in Selected Countries
