This paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...

This article considers the nature of the relationship between domestic thin capitalization rules and the non-discrimination article in the OECD Model, with a particular focus on foreign ownership and article 24(5). In this context a question arises regarding the interpretation of article 24(5)...