Discussion of circumstances in which fictitious income may fall under the income allocation provisions (Arts. 6-20) of an OECD Model-type tax treaty, the "other income" provision (Art. 21 OECD Model), or outside the scope of the treaty entirely.
Discussion of circumstances in which fictitious income may fall under the income allocation provisions (Arts. 6-20) of an OECD Model-type tax treaty, the "other income" provision (Art. 21 OECD Model), or outside the scope of the treaty entirely.