Abstract
The tax treaty treatment of severance payments in relation to private employment in a cross-border context is described in this article. Qualification and allocation issues are examined, including the inherent risks of double taxation or double non-taxation in relation to such issues. Subsequently, the author highlights new developments brought about in the OECD Model (2014) and related Commentary on this topic and assesses the strengths and shortcomings of these developments. Finally, Switzerland is used as an example.
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