Unfinished Business: Domestic Thin Capitalization Rules and the Non-Discrimination Article in the OECD Model
Journal
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2013 (Volume 67), No. 1
Document
This article considers the nature of the relationship between domestic thin capitalization rules and the non-discrimination article in the OECD Model, with a particular focus on foreign ownership and article 24(5). This question is addressed in an international context with reference to recent relevant tax cases.