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21 September 2015 / press release

Alexander Bosman receives doctorate

Alexander Bosman, tax adviser at Loyens & Loeff, defends his thesis entitled "Other Income under Tax Treaties; An Analysis of Article 21 of the OECD Model Convention" at the VU University Amsterdam on 22 September 2015.

Employment agreements concluded by means of an electronic signature

The thesis deals with the application of bilateral tax treaties, of which there are currently more than 3,000 worldwide. The primary purpose of such treaties is to prevent situations in which two countries want to tax the same income (which can hinder cross-border activities and investments). Using tax treaties, the two countries concerned divide their rights to tax various types of income. These distributive rules are concluded by a residual provision: the so-called ‘other income’ article (Article 21 of the OECD Model Tax Convention).

Article 21

Alexander Bosman: "No large-scale study of Article 21 has been published in the last 25 years. However, the ‘other income’ article is relevant in relation to all other categories of income described in a tax treaty, because it is interwoven with all the other articles of the tax treaty. The importance of properly understanding Article 21 therefore fits in the wider context of treaty interpretation. My research aims to contribute to a proper interpretation and application of tax treaties, among other things by making proposals for amending the OECD Model Tax Convention and the Commentaries thereon. The recent huge increase in (media) attention for tax treaties – see for example the OECD and G20 countries’ current BEPS project to tackle tax avoidance by multinationals – underlines the importance of a proper understanding of how tax treaties function.”