The Resource At sixes and sevens : the relationship between the taxation of business profits and income from immovable property under tax treaties

At sixes and sevens : the relationship between the taxation of business profits and income from immovable property under tax treaties

Label
At sixes and sevens : the relationship between the taxation of business profits and income from immovable property under tax treaties
Title
At sixes and sevens : the relationship between the taxation of business profits and income from immovable property under tax treaties
Creator
Subject
Language
eng
Summary
This article discusses the relationship between Art. 6 (Income from immovable property) and Art. 7 (Business profits) of the OECD Model Tax Convention. The issue examined is whether it is appropriate for Art. 6 to apply in preference to Art. 7 in all circumstances. After an overview of Arts. 6 and 7, the article considers the potential overlap between them, which involves the situation where immovable property constitutes a permanent establishment under Art. 5 and where income from immovable property constitutes business profits. The article also examines the relationship between Art. 6 and the other distributive articles of the OECD Model to see if those relationships provide any insight into the proper relationship between Arts. 6 and 7. The implications of the OECD Discussion Draft on the Attribution of Profits to Permanent Establishments for the relationship between Arts. 6 and 7 is explored briefly. The article concludes that it is inappropriate for Art. 6 always to trump Art. 7 and considers some possible changes to modify that result
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 60 (2006),
http://library.link/vocab/creatorName
Arnold, B.J
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD Model
  • business income
  • tax treaty
  • immovable property
  • PE
Label
At sixes and sevens : the relationship between the taxation of business profits and income from immovable property under tax treaties
Instantiates
Publication
Label
At sixes and sevens : the relationship between the taxation of business profits and income from immovable property under tax treaties
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...