A cross-border pipeline is probably one of the most complex assets to be found, as it can cross several borders and boundaries or even be laid in transit states. Such a unique and complex asset creates very intricate tax issues. This study offers an in-depth discussion of the principal questions: How is a cross-border pipeline currently characterised according to the OECD Model Tax Treaty and its Commentaries? How is income from a cross-border pipeline allocated between the states involved and does the OECD?? authorised ?
