Comments on Article 15 of the OECDMC: Income from Labour Work

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Universidad Carlos III de Madrid
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The clause of income from labour work contained in article 15 of the OECDMC has not changed much in the latest years. The main changes have been included as an Anti-avoidance rule in the computation of days abroad or by including and special clause on the taxation of the income received by the crew of ships and aircraft engaged in international traffic. More substantial changes has happened in the Commentaries to the article as they have been evolving as new sources of remuneration where appearing for this kind of work. In this regard, the commentaries have included clauses on severance payments, bonus payments and stock option payments. Additionally, commentaries have also included some interpretation on certain situation such us the hiring of employees by intermediary entities that are resident in different states from the residency of the employee and the place where the worker is performing its services. This different interpretations that are included in the commentaries as well as the small changes that the article 15 has suffered during the latest years have its reflect on the Ibero-American network of DTTS. The aim of this paper is to identified and describe these differences and the effects they might have in the taxation of the income from labour work.
Art. 15 OECD MC, Income from Labour work, Ibero-American network of DTTs, International taxation, OECD model tax convention
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Marcos Jubilar, C. (2022). Comments on Article 15 of the OECDMC: Income from Labour Work. Working Papers of the Iberoamerican Observatory of International Taxation. Commentaries to the Iberoamerican Tax Treaty Network, 2022-01. Universidad Carlos III de Madrid