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

Bibliographic Information

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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Description and Table of Contents

Description

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.

Table of Contents

  • 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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