New provision for the United Nations Model Double Taxation Convention between Developed and Developing Countries to address the application of tax treaties to payments made through hybrid entities : note / by the Secretariat
2015
Files
Details
SymbolE/C.18/2015/3
TitleNew provision for the United Nations Model Double Taxation Convention between Developed and Developing Countries to address the application of tax treaties to payments made through hybrid entities : note / by the Secretariat
AccessEnglish: E_C.18_2015_3-EN - PDF ; Español: E_C.18_2015_3-ES - PDF ; Français: E_C.18_2015_3-FR - PDF ; Русский: E_C.18_2015_3-RU - PDF ; العربية: E_C.18_2015_3-AR - PDF ; 中文: E_C.18_2015_3-ZH - PDF ;
AuthorsUN. Secretariat
Agenda information
E/C.18/2015/1 3a(i) Article 1 (Persons covered): application of treaty rules to hybrid entities.
Date[New York] : UN, 10 Aug. 2015
Description
19 p.
Notes
Annexes (p. 4-19): 1. United Nations Model Double Taxation Convention between Developed and Developing Counries: proposed changes to address the application of tax treaties to payments made through hybrid entities -- 2. Examples of possible tax treaty issues arising in the context of payments made through a hybrid entity -- 3. Extracts from the United States Model Technical Explanation for corresponding tax treaty provisions.