9.3.3. Testing production sharing payments and their coverage under article 2 OECD Models -- 9.4. Specific taxes in the financial industry -- 9.4.1. The financial industry and its specific taxes -- 9.4.2. Bank levies and their coverage under article 2 OECD Models -- 9.4.3. FATs and their coverage under article 2 OECD Models -- 9.4.4. FTTs and their coverage under article 2 OECD Models -- 9.5. Conclusions -- Chapter 10: Double Protection under Article 2 OECD Model Convention 1982 and 2017? -- 10.1. The OECD Model 1982 and 2017 -- 10.2. Article 2(1) and (2) OECD Model 1982 and 2017 -- 10.2.1. The general definition in article 2(1) and (2) OECD Models -- 10.2.2. The relation between the two model conventions -- 10.2.3. Delimitation between taxes on income and on capital and taxes on estates, inheritances and gifts -- 10.3. The importance of article 2(3) and (4) OECD Models 1982 and 2017 -- 10.3.1. The list of taxes according to article 2(3) OECD Models -- 10.3.2. The amplifying power of article 2(3) OECD Models -- 10.3.3. The relation between the two model conventions -- 10.4. Conclusion and outlook -- Chapter 11: Tax Treaty Application beyond the Scope of Article 2 OECD Model Convention 1982 and 2017 (Mutual Agreement, Non-Discrimination, Mutual Assistance) -- 11.1. Introduction -- 11.2. MAP beyond the substantive scope of the OECD Models 1982 and 2017 -- 11.2.1. The MAP beyond the scope of the convention -- 11.2.2. Meaning of double taxation -- 11.2.3. Meaning of "not provided for in the Convention" -- 11.3. Mutual assistance clauses under the OECD Model 2017 -- 11.3.1. Commonality, relationship and subject of the mutual assistance clauses -- 11.3.2. Article 26 of the OECD Model 2017 -- 11.3.3. Article 27 of the OECD Model 2017 -- 11.4. Non-discrimination clauses -- 11.4.1. |