Method articles
As methods Article Articles in are double taxation agreements referred, which say how the state of residence, the double taxation avoiding, if the other Contracting State income or capital taxed. They complement the distribution norms that define whether one or both contracting states have a right to tax. In the case of “complete” or “exclusive” distribution norms, the right to tax is only assigned to one state, whereas the “incomplete” or “non-exclusive” distribution norms grant both contracting states a certain right to tax.
Systematically, the credit method and the exemption method are the two main methods of avoiding double taxation . The model agreement of the OECD (OECD-MA) contains the credit method in Art. 23 B OECD-MA and the exemption method in Art. 23 A OECD-MA.
Individual evidence
- ↑ Madeleine Simonek, in: Zweifel / Beusch / Matteotti (ed.), Commentary on international tax law, Art. 23 A, B OECD-MA N 3
