Source Versus Residence

This book on ‘Source versus Residence: The Allocation of Taxing Rights in Tax Treaty Law – Problems arising from the Existing Tax Treaty Provisions and Possible Alternatives’ is an analysis of the allocation rules of the OECD Model Tax Convention and their equivalents in bilateral tax treaties. This book specifically focuses on interpretation and application problems and proposes possible alternatives.

The Present Publication, authored by Michael Lang, Pasquale Pistone, Josef Schuch and Claus Staringer, is the latest edition, with the following noteworthy features:

• This book is a compilation of papers, written by tax experts from different parts of the world, on each allocation rule. It incorporates discussion and critical comments of renowned scholars and tax practitioners, along with their oral contributions.
• The book discusses the following:
  • Interpretation and application problems of the allocation rules of OECD Model Tax Convention
  • How the allocation rules could be changed in order solve the problems
  • Whether these allocation rules are justified?
  • What alternatives exist for these allocation rules?

The contents of this book are as follows:

• Ekkehart Reimer | Income from Immovable Property (Article 6 OECD Model Convention)
• Reuven S. Avi-Yonah and Kimberly A. Clausing | Business Profits (Article 7 OECD Model Convention)
• Guglielmo Maisto | Shipping Inland Waterways Transport and Air Transport (Article 8 OECD Model Convention)
• Alexander Hemmelrath | Discussion of Guglielmo Maisto’s Paper on Article 8 OECD Model Convention
• Stef van Weeghel | Dividends (Article 10 OECD Model Convention)
• Marjaana Heminen | Discussion of Stef van Weeghel’s Paper on Article 10 OECD Model Convention
• Robert Danon | Interest (Article 11 OECD Model Convention)
• Niv Tadmore | Royalties (Article 12 OECD Model Convention)
• Stefano Simonntacchi | Capital Gains (Article 13 OECD Model Convention)
• Richard Krever | Discussion on Stefano Simontacchi’s Paper on Article 13 OECD Model Convention
• Rober Waldburger | Income from Employment (Article 15 OECD Model Convention)
• Rainer Prokisch | Director’s Fees (Article 16 OECD Model Convention)
• Daniel Sandler | Artistes and Sportsmen (Article 17 OECD Model Convention)
• Dick Molenaar | Discussion of Daniel Sandler’s Paper on Article 17 OECD Model Convention
• Eric C.C.M. Kemmeren | Pensions (Article 18 OECD Model Convention)
• Pasquale Pistone | Government Service (Article 19 OECD Model Convention)
• Luc De Broe | Students (Article 20 OECD Model Convention)
• Alexander Rust | Other Income (Article 21 OECD Model Convention)
• Frank Pötgens and Alexander Bosman | Discussion of Alexander Rust’s Paper on Article 21 OECD Model Convention