Andy Cools, Arcalius, Opglabbeek, Belgium: Directors fees in an ...

More documents

Recommendations

Info

Article 16 OECD The wording of the OECD Model Tax Convention and the UN Model Convention follows the same pattern. But: UN MC, in addition, has a second paragraph with a provision on payments in respects of top level managerial positions of a company. The US MC contains also a provision corresponding to article 16 OECD and UN MC (2006 Model tax Convention). Difference = services rendered in the other contract state. Physical presence, cfr. Article 15 OECD.
Article 16 OECD Some terms are not obvious (Director? Fee? Board of directors?) Application of legal rules requires interpretation. Interpretation is an art which itself is subject to legal rules. The starting point for tax treaty interpretation is the question which standards apply for the interpretation of international law in general (Convention of Vienna)
Page 1 and 2: Andy COOLS
Page 3: Article 16 OECD This article relate
Page 7 and 8: Article 16 OECD New double tax conv
Page 9 and 10: Article 16 OECD B. What kind of dir
Page 11 and 12: Article 16 OECD Other functions: a

Andy Cools, Arcalius, Opglabbeek, Belgium: Directors fees in an ...

Create successful ePaper yourself

Delete template?

Save as template?