Organisation of Economic Co-operation and Development, 2014, “Model Convention with Respect to Taxes on Income and Capital.”, (Paris: OECD.)
United Nations, 2011, “Model Double Taxation Convention between Developed and Developing Countries (Update).” United Nations Department of Economic & Social Affairs; (New York: United Nations.)
Prepared by Aqib Aslam, Geerten Michielse, and Christopher J. Heady.
This paper does not cover taxation of oil investments.
Comparator economies—based on nominal GDP, population, nominal GDP per capita, GDP at purchasing power parity, and GDP at market prices—are Colombia, Egypt, Philippines, Poland, South Africa, Thailand, and Turkey.
A highly-leveraged company—one with a high debt-to-equity ratio—is “thinly capitalized.”
Recommended by the OECD in BEPS Action 4: Limiting Base Erosion Involving Interest Deductions and Other Financial Payments.
Article 107 and the IDTA By-Law.
China, South Africa, France, and Turkey. Iran is currently negotiating a DTT with the Netherlands.
Currently Iran has 43 DTTs in force, 9 DTTs are concluded but not yet in force, and 8 DTTs are under negotiation. Some DTTs were negotiated but did ultimately not result in the conclusion of a DTT.