International taxation of dividends reconsidered in light of corporate tax integration : proceedings of a seminar organised jointly with OECD in Toronto in 1994 during the 48th Congress of the International Fiscal Association

書誌事項

International taxation of dividends reconsidered in light of corporate tax integration : proceedings of a seminar organised jointly with OECD in Toronto in 1994 during the 48th Congress of the International Fiscal Association

(IFA Congress seminar series, v. 19a)

Kluwer Law International, c1995

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内容説明

These proceedings of "The OECD Model Convention 1994 and Beyond" held in Toronto open with a report on OECD work relating to the Convention and its Official Commentary. They discuss the necessity and possibility of adapting Article 10 of that model to tax systems with corporate tax integration.

目次

  • Amending the OECD Model Treaty and Commentary in response to corporate tax integration
  • Article 10 of the OECD Model Tax Convention and the different approaches to integration
  • in a world where classical and integration systems co-exist, Article 10 OECD Model should not disregard the underlying corporation income tax
  • an optimum form of Article 10 of the OECD Model.

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