Director's fees taxation; collége des commissaires; Article 16 OECD
Abstract :
[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.
Disciplines :
Tax law
Author, co-author :
Haslehner, Werner ; University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit
External co-authors :
no
Language :
English
Title :
Luxembourg: Applying Article 16 to a “Collège des Commissaires”
