Quotation Knotzer, Christian. 2021. Taxes on Capital According to Article 2(1) and (2) OECD Model Convention 2017. In: Taxes Covered under Article 2 of the OECD Model, Hrsg. Georg Kofler; Michael Lang; Pasquale Pistone; Alexander Rust; Josef Schuch; Karoline Spies; Claus Staringer, 45-76. Amsterdam: IBFD.


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Abstract

This contribution focuses on taxes on capital according to Art 2 (1) and Art 2 (2) of the OECD MC 2017. In the first part of the contribution, Art 2 and Art 22 of the OECD MC are analyzed in detail and it is illustrated that there is a considerable number of unresolved issues in this regard. Thereafter, a comprehensive historical analysis of taxes on capital in Model Conventions for the avoidance of double taxation is provided. In the following the question will be examined whether there is a terminological distinction between the terms "capital" and "property". This issue is addressed and critically appraised with reference to the aforementioned historical insight, the system of the OECD MC 2017 and its commentary, past case law and the pertinent literature. This contribution closes with concluding remarks and shows that taxes on capital within Art 2 OECD MC 2017 deserve more scientific attention.

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Publication's profile

Status of publication Published
Affiliation WU
Type of publication Chapter in edited volume
Language English
Title Taxes on Capital According to Article 2(1) and (2) OECD Model Convention 2017
Title of whole publication Taxes Covered under Article 2 of the OECD Model
Editor Georg Kofler; Michael Lang; Pasquale Pistone; Alexander Rust; Josef Schuch; Karoline Spies; Claus Staringer
Page from 45
Page to 76
Location Amsterdam
Publisher IBFD
Year 2021
URL https://www.ibfd.org/IBFD-Products/Taxes-Covered-under-Article-2-OECD-Model
ISBN 978-90-8722-671-8
Open Access N

Associations

People
Knotzer, Christian (Details)
Organization
Institute for Austrian and International Tax Law IN (Details)
Research areas (Ă–STAT Classification 'Statistik Austria')
5206 Financial law (Details)
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