Everything about Triangular Cases

We have repeatedly discussed how corporate and multinational entities have creatively used the tax treaties to reduce their overall tax liabilities. One such measure is a typical “Triangular case” where three countries are involved, the State of residence of the entity, the State of the Source, and the State where the Permanent establishment is resident … Continue reading Everything about Triangular Cases →

Understanding the Credit Method | Article 23B of the OECD Model Tax Convention

OECD model tax convention Credit Method

Article 20 | Taxation of Students | OECD Model Tax Convention

Junaid, like every other person from a developing nation, has a ‘Big America’ dream. Looking at his tenacity, his employers have sponsored his education and maintenance at Harvard University. He continues to receive the fees and living expenses from his employer in Brazil. Junaid is worried about high-income tax rates in the USA? Will this … Continue reading Article 20 | Taxation of Students | OECD Model Tax Convention →

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Income from Interest| Article 11 | OECD Model Tax Convention

Interest is commonly known as the income earned on the movable capital. Unlike dividends, interest does not suffer the economic double taxation and is not taxed both at the hands of the debtor and the creditor. The payer of the interest gets the deduction, whereas the recipient has to discharge taxes. Article 11 of the … Continue reading Income from Interest| Article 11 | OECD Model Tax Convention →

Article 10 | Dividends | OECD Model Tax Convention

Article 10 of the OECD Model Tax Convention covers taxation rights of the States. Dividends In this post, we will cover the following: What is the dividend?Who has the right to tax dividends?Explain the term dividend as per Article 10When not to apply Paragraphs 1 and 2 of Article 10?What is extra-territorial taxation of dividends? … Continue reading Article 10 | Dividends | OECD Model Tax Convention →

Business Profits | Article 7 | OECD Model Tax Convention

Article 7 of the OECD Model Tax Convention covers Business Profits

International Shipping and Air Transport | Article 8 | OECD Model Tax Convention

Article 8 of the OECD Model Tax treaty covers International Shipping and Air Transport

Immovable Property | Article 6 | OECD Model Tax Convention

Lara is from London, who owns a beautiful lake house offering bed and breakfast in Spain. She is wondering whether her income from the property is from the income from immovable property (real property) or not. Let's try to understand what is income from real (immovable property). If running short of time, you can listen … Continue reading Immovable Property | Article 6 | OECD Model Tax Convention →