Recent Developments and Challenges Regarding Exit Taxes in the Context of Tax Treaties: Article 13 of the OECD Model and Change of Residence
Journal
Country
International; OECD; South Africa
Published Date
Issue
Bulletin for International Taxation 2019 (Volume 73), No. 10
Document
In this article, the author considers whether article 13(5) of the OECD Model applies to exit taxes and whether it precludes the application of exit taxes. The author also examines to what extent tax treaties can mitigate the risk of double taxation with regard to exit taxes.