The Application of the OECD Model Tax Convention to Partnerships

The application of tax treaties to cases involving partnerships raises a number of complex issues. When is a partnership entitled to the benefits of a tax convention? What happens when the residence and source States apply different articles of the Convention on the basis of differences in their domestic law? How can the problems arising from conflicts of income allocation be solved? This report addresses these issues in detail and focuses on specific factual examples. For each example, the facts and, where applicable, relevant aspects of domestic tax laws are described. Comprehensive recommendations for dealing with the international taxation of partnerships in practice are also presented.