In his seminal works regarding the application of tax treaties to partnerships, Michael Lang shows convincingly that the solutions offered by the OECD are not always persuasive. He proposes solutions which are based on a sound interpretation of the tax treaties. As the application of tax treaties to CFC legislation is based on similar principles, he transposes his findings regarding partnerships to CFC legislation. In this article, Alexander Rust questions whether income attributed to the parent entity falls within the ambit of Article 10 OECD MC.
