1. OECD Model Treaty and Commentary: 2014 Update: Share redemptions

• Source country treatment as "income from shares" requires that Article 10, not 13, applies

• Residence country must accept that treatment, for purposes of Articles 23A and 23B

2. OECD Model Treaty and Commentary: 2014 Update: Accrued interest

• Definition of "interest" in Article 11

• Amended Commentary: sale of security for price which reflects accrued interest, redemption premium, or original issue discount

3. OECD Model Treaty and Commentary: 2014 Update: "Look through" rule for conduit companies?

• Amendments to Model Treaty and Commentary in regard to "beneficial ownership" do not provide for an express "look through" rule for conduit companies

4. Cases

• India: MISC case

• Article 8 of India / Malaysia treaty

• Slot-chartering arrangement

• For information:

N.C. Hegde (Mumbai): [email protected]

K.R. Sekar (Bangalore): [email protected]

5. In brief

• Treaties

- Singapore / Liechtenstein enters into force

• Taiwan

- R&D tax credits and other incentives: now require compliance with environmental, labor, and food safety laws

- For information:

Cheli Liaw (Taipei): [email protected]

• India

- Cairn: moves its "indirect share transfer" case to new committee

- For information:

N.C. Hegde (Mumbai): [email protected]

K.R. Sekar (Bangalore): [email protected]