An Argument for Treating Distributions by Austrian Private Foundations to Foreign Beneficiaries as Dividends under Tax Treaties Based on the OECD Model

Bergmann, S.

An Argument for Treating Distributions by Austrian Private Foundations to Foreign Beneficiaries as Dividends under Tax Treaties Based on the OECD Model

Journal

Author

Bergmann, S.

Country

Austria; OECD

Published Date

31 July 2020

Issue

Bulletin for International Taxation 2020 (Volume 74), No. 8

DOI

https://doi.org/10.59403/145xb5d

Document

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This article presents an argument that distributions paid by Austrian private foundations to foreign beneficiaries should be treated as dividends rather than as other income under Austrian tax treaties that are based on the OECD Model.

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An Argument for Treating Distributions by Austrian Private Foundations to Foreign Beneficiaries as Dividends under Tax Treaties Based on the OECD Model