Distribution norms

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The articles in double taxation agreements that state whether only one or both contracting states have the right to tax are referred to as distribution norms (also limit norms ) . 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. In the case of "incomplete" or "non-exclusive" distribution standards requires the Methods Product to the double taxation should be avoided. The method articles state how the state of residence avoids double taxation when the other contracting state also taxes income or assets.

In the OECD Model Convention (OECD-MA), Articles 6–22 are distribution standards.

Individual evidence

  1. ^ Brähler, Gernot (2014). International tax law: Basics for studies and tax advisor examination. Springer Gabler. P. 104 ff.
  2. Madeleine Simonek, in: Zweifel / Beusch / Matteotti (ed.), Commentary on international tax law, Art. 23 A, B OECD-MA N 1