Model Tax Convention on Income and on Capital: Condensed Version 2017
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Model Tax Convention on Income and on Capital: Condensed Version 2017

This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the articles and commentaries of the Model Tax Convention on Income and Capital as it read on 21 November 2017, but without the historical notes and the background reports that are included in the full version.

The full version of the OECD Model Tax Convention for each edition is published separately. It is available in print, PDF and web formats. The web format includes extensive interlinking, making it easy to link from articles to related commentaries. The web and PDF versions will be available via the OECD iLibrary.

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Commentary on Article 11 You do not have access to this content

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OECD

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“Interest” is generally taken to mean remuneration on money lent, being remuneration coming within the category of “income from movable capital” (revenus de capitaux mobiliers). Unlike dividends, interest does not suffer economic double taxation, that is, it is not taxed both in the hands of the debtor and in the hands of the creditor. Unless it is provided to the contrary by the contract, payment of the tax charged on interest falls on the recipient. If it happens that the debtor undertakes to bear any tax chargeable at the source, this is as though he had agreed to pay his creditor additional interest corresponding to such tax.

 
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