The right to redemption as a key characterization factor in the OECD Model Convention passive income taxation system - the case of reverse convertibles

Journal
Rotondaro, C.
Germany; Netherlands
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2000 (Volume 2), No. 5
FormatPDF
EUR
40
| USD
45
(VAT excl.)

Commentary on and analysis of two official notes addressed by the Dutch and German Ministry of Finance, stating the position of the corresponding tax administrations on the topic. Deals with the treaty characterization issues.