According to Chat-gpt:
The statement:
"Eliminating international double taxation on income and capital without creating opportunities for non-taxation or reduced taxation through complying with the key substantive conditions underlying the OECD Model Tax Convention"
primarily concerns companies, but it can also apply to individuals, depending on the context.
Here’s a breakdown:
Primary Focus: Companies (Multinational Enterprises)
This language is closely aligned with OECD Base Erosion and Profit Shifting (BEPS) initiatives.
It targets corporate tax planning strategies that exploit gaps and mismatches in tax rules (e.g., treaty shopping, artificial profit shifting).
The goal is to:
Avoid double taxation where the same income is taxed in two jurisdictions.
But prevent abuse where entities reduce or avoid taxation entirely (double non-taxation or under-taxation).
Example:
A multinational sets up a shell company in a tax treaty jurisdiction to benefit from a treaty's lower withholding tax rate—despite having no real economic activity there. The OECD aims to stop this kind of abuse.
Secondary Relevance: Individuals
For individual taxpayers, especially cross-border workers or investors, double taxation agreements (DTAs) based on the OECD Model Convention:
Prevent income (e.g., salaries, pensions, dividends) from being taxed twice.
Allocate taxing rights between residence and source countries.
However, the language in your quote is more technical and policy-driven, typical of corporate anti-avoidance frameworks—not standard individual-level tax relief.
Conclusion:
The statement mainly concerns companies, especially multinational corporations, and reflects efforts to strike a balance between:
Preventing double taxation (legitimate relief),
While blocking abuse of treaties to achieve double non-taxation or artificial tax advantages.
If you have a specific use case (individual investor, business owner, etc.), I can narrow it further.