Unfinished Business: Domestic Thin Capitalization Rules and the Non-Discrimination Article in the OECD Model

Journal
Author
Elliffe, C.
Country
International; OECD
Published Date
Issue
Bulletin for International Taxation 2013 (Volume 67), No. 1
FormatPDF
EUR
45
| USD
50 (VAT excl.)

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.