The international tax system has always reflected a tension between residence and source taxation from its very beginnings in the 1920s when the first model treaties were devised. After several decades of relative quietude on this front we are currently witnessing a new struggle over...

This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. These changes and their implementation warrant an assessment of their desirability, including an in-depth...

2008 was a significant year for scholars interested in the history of tax treaties. Apart from the Rust tax treaties history conference, the main event was the release of the OECD archives in September when the OECD celebrated the 50th anniversary of the OECD Model (or more accurately the...

This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. These changes and their implementation warrant an assessment of their desirability, including an in-depth...

This paper consider the history of the tax treaty rule on royalties up to the emergence of the modern form, the borders of the provision and the fundamental question of why we have it (viewed from an historical perspective). In the modern context of the OECD Model with zero taxation at source on...

The publication of the OECD Model tax treaty in 1977 marked 50 years of development. The Model seeks to remove international tax barriers by reconciliation at the interface of tax systems and has produced a bilateral network because it is generally considered that the diversity of tax systems...