Commentary. Example 3 raises the potential for tax avoidance arising from remit- tance-based taxation. This issue is dealt with in paragraph 26.1 of the Com- mentary on Article 1 of the OECD Model Convention, which suggests that, in order to deal with such situations, countries may include a specific anti-abuse provision in their tax treaties with countries that allow that form of taxation:
Appears in 3 contracts
Sources: Double Taxation Convention, Double Taxation Convention, Double Taxation Convention