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

Marcos Jubilar, Clara

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

ah.contributor.editor	Observatorio Iberoamericano de Tributación Internacional (OITI)	es
dc.affiliation.area	UC3M. Área de Derecho Financiero	es
dc.affiliation.dpto	UC3M. Departamento de Derecho Público del Estado	es
dc.contributor.author	Marcos Jubilar, Clara
dc.date.accessioned	2022-07-07T09:37:26Z
dc.date.available	2022-07-07T09:37:26Z
dc.date.issued	2022-07-07
dc.description.abstract	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.	es
dc.identifier.bibliographicCitation	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	es
dc.identifier.issn	2659-8183
dc.identifier.uri	https://hdl.handle.net/10016/35419
dc.language.iso	eng	es
dc.publisher	Universidad Carlos III de Madrid	es
dc.relation.ispartofseries	Working papers of the Iberoamerican Observatory of International Taxation. Commentaries to the Iberoamerican Tax Treaty Network	es
dc.relation.ispartofseries	22/01	es
dc.rights	Atribución-NoComercial-SinDerivadas 3.0 España	*
dc.rights.accessRights	open access	es
dc.rights.uri	http://creativecommons.org/licenses/by-nc-nd/3.0/es/	*
dc.subject.eciencia	Derecho	es
dc.subject.other	Art. 15 OECD MC	es
dc.subject.other	Income from Labour work	es
dc.subject.other	Ibero-American network of DTTs	es
dc.subject.other	International taxation	es
dc.subject.other	OECD model tax convention	es
dc.title	Comments on Article 15 of the OECDMC: Income from Labour Work	es
dc.type	working paper	*
dc.type.hasVersion	SMUR	*
dspace.entity.type	Publication