Tax Treaty Treatment of Dividend Related Payments under Share Loan Agreements

Publikation: Bidrag til tidsskriftTidsskriftartikelForskningpeer review

Resumé

The article analyses some of the qualification and allocation challenges that dividend related payments under share loan agreements give rise to for tax treaty purposes. The analysis is based on constructed scenarios illustrating how inconsistent domestic allocation of the dividend related payments give rise to
qualification and allocation conflicts for tax treaty purposes in cross-border situations. The main challenges concern to what extent dividend related payments may be covered by the term “dividends” in article 10 of the OECD double tax convention and to what extent the lender in a share loan agreement
fulfils the beneficial ownership requirement.
OriginalsprogEngelsk
TidsskriftWorld Tax Journal
Vol/bind6
Udgave nummer2
Antal sider19
ISSN1878-4917
StatusUdgivet - 2014

Citer dette

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Tax Treaty Treatment of Dividend Related Payments under Share Loan Agreements. / Dyppel, Katja Joo.

I: World Tax Journal, Bind 6, Nr. 2, 2014.

Publikation: Bidrag til tidsskriftTidsskriftartikelForskningpeer review

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