Articolul 11 din Conventiile Model OCDE si ONU

The following paper analyses the provision of article 11 form of OECD and UN Model Conventions. Article 11 is used in both Model Conventions in order to regulate the taxation of interest incomes derived from cross-border relations. In the same time, the reader shall be informed on the way Romania has understood to regulate the taxation of the interest incomes within the double taxation convention it became party to. After more than 75 years of regulation, having as a result the compromise established between states which conclude double taxation convention, the taxation of income derived from interests is far from being complete. Some of the related loopholes are presented below. [PUBLICATION ABSTRACT]