OECD Model Tax Convention on Income and on Capital: Condensed Version. Paris, OECD Publishing, 2014. Art. 23. P. 36–37.
1545
Ibid. Commentary to Art. 1. § 23. P. 72.
1546
Peter Harris, David Oliver. International Commercial Tax. Cambridge University Press, 2010. P. 304.
1547
OECD Model Tax Convention on Income and on Capital: Condensed Version. Paris, OECD Publishing, 2014. Commentary to Art. 7. § 14. P. 136.
1548
Ibid. Art. 10. § 1. P. 30: «1. Dividends paid by a company which is a resident of a Contracting State to a resident of the other Contracting State may be taxed in that other State».