The present survey analyses for the first time the problem complex of double taxation due to not coordinated shareholder debt-financing rules in all thirty Organization of Economic Cooperation and Development (OECD) Member States by means of cross-border tax assessment simulations for all double taxation cases in the OECD. The survey shows that there exists a considerable tax differential within the OECD that gives the incentive for international tax planning using shareholder debt financing. All 870 relations between OECD Member States are examined and the enormous extent of potential double taxation due to shareholder debt-financing rules within the OECD is shown. Therefrom, recommendations for the further development of the OECD Model are deducted that are measured by the objective of fair apportionment of tax revenues, the objective of avoidance of double taxation, the objective of community law conformity, and the objective of feasibility. As realistically as possible, nobody can expect a further development of the OECD Model to solve the problem of double taxation due to not coordinated shareholder debt-financing rules in the near-future recommendations for international tax planning are deducted
Intertax