Wednesday, April 18, 2007
Michael Lang (Vienna University) presented OECD Model Convention – Can Complexity Be Reduced? at Michigan yesterday as part of its Tax Policy Workshop Series hosted by Reuven S. Avi-Yonah, James R. Hines, Jr., and Sagit Leviner. Here is the Conclusion:
Reducing the complexity of the OECD MC seems to be possible. However, only a step-by-step approach is realistic. The ideas raised in this contribution are meant to provoke discussion. It would be helpful to conduct a careful examination of whether the motives for the introduction of the various allocation rules are still valid, and, if this is no longer the case, which other arguments may justify their existence.