Chapter 8: Tax Treaty Entitlement and Hybrid Entities: Article 1(2) and Article 1(3) of the OECD Model (2017)
Why this work is in the frame
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Bibliographic record
Abstract
Why this book? The entitlement to tax treaty benefits is of pivotal importance for taxpayers in order to obtain treaty benefits. However, the application and interpretation of the respective tax treaty provisions are not always straightforward and may often raise various questions. This is all the more true now that the OECD has introduced a number of new provisions regarding the entitlement to tax treaties into its Model Convention as part of the BEPS Project. This book analyses several crucial areas concerning the entitlement to tax treaties. The topics covered include: The application of the principal purpose test, limitation on benefits clauses and the beneficial ownership test The relevance of the term “person” within the OECD Model Dual residence for individuals and non-individuals The tax treaty entitlement of hybrid entities The entitlement to protection against discriminatory taxation The personal scope of the mutual agreement procedure and arbitration provisions, and the mutual assistance provisions Downloads Sample excerpt, including table of contents This book is part of the WU Institute for Austrian and International Tax Law – Tax Law and Policy Series View other titles in the series Editor(s) Michael Lang, Pasquale Pistone, Alexander Rust, Josef Schuch and Claus Staringer are professors at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). Contributor(s) Desiree Auer, Peter Bräumann, Svitlana Buriak, Karol Dziwiński, Sriram Govind, Michael Lang, Clement Okello Migai, Florian Navisotschnigg, Claire (Xue) Peng, Pasquale Pistone, Lisa Maria Ramharter, Alexander Rust, Josef Schuch, Claus Staringer, Rita Szudoczky, Michael Tumpel, Jean-Philippe Van West.
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Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.000 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.000 |
| Science and technology studies | 0.000 | 0.001 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from it