The topics of double non-taxation and hybrid entities have acquired a particular importance in a context where transformations within the tax world seem to be leading to an international commitment most materially manifested in the OECD Base Erosion and Profit Shifting (BEPS) project. In this...

This paper analyzes the differences in legal nature between the common law concept of Agency and the civil law concept of Commissionaire in light of articles 5(5) and 5(6) of the OECD Model Tax Convention. The author contradicts the idea of interpreting the civil law concept of Commissionaire is...

The benefits of a tax treaty are generally granted to persons who are residents of one of the Contracting States. The determination of such tax residence status is, however, not always an easy task and is particularly problematic in relation to entities whose tax characterisation differs from...