Reference : Luxembourg: Applying Article 16 to a “Collège des Commissaires”
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Luxembourg: Applying Article 16 to a “Collège des Commissaires”
Haslehner, Werner mailto [University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit >]
Tax Treaty Case Law around the Globe 2016
Kemmeren, Eric
Smit, Daniel
Essers, Peter
Lang, Michael
Pistone, Pasquale
Schuch, Joseph
Staringer, Claus
Storck, Alfred
Owens, Jeffrey
Rust, Alexander
[en] Director's fees taxation ; collége des commissaires ; Article 16 OECD
[en] This case note examines a decision by the Cour administrative of Luxembourg concerning the qualification of the fees earned by a commissaire of a partnership limited by shares under the Luxembourg-South Africa tax treaty. It concludes that, while the result of the judgment is unobjectionable, it failed to explore the boundaries of the meaning of the term "director" in ways that could give clearer indications for other cases.
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