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1 August 2014
OECD Model Treaty and Commentary: 2014 Update: Share redemptions
Source country treatment as "income from shares" requires that Article 10, not 13, applies
Residence country must accept that treatment, for purposes of Articles 23A and 23B
OECD Model Treaty and Commentary: 2014 Update: Accrued interest
Definition of "interest" in Article 11
Amended Commentary: sale of security for price which reflects accrued interest, redemption premium, or original issue discount
OECD Model Treaty and Commentary: 2014 Update: "Look through" rule for conduit companies?
Amendments to Model Treaty and Commentary in regard to "beneficial ownership" do not provide for an express "look through" rule for conduit companies
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