The Resource Income from immovable property - preserving the situs and the permanent establishment principles

Income from immovable property - preserving the situs and the permanent establishment principles

Label
Income from immovable property - preserving the situs and the permanent establishment principles
Title
Income from immovable property - preserving the situs and the permanent establishment principles
Creator
Subject
Language
eng
Summary
It is accepted that tax treaties should allocate primary taxing rights over immovable proporty and income from immovable propery to the situs state; the state in which a taxpayer has a permanent establishment (PE) should have priority over the state of its residence in so far as the taxation of income attributable to that PE is concerned. However, structural inconsistencies within tax treaties prevent these policies from being reconciled, which may enable tax avoidance. In analysing the relevant historical documents, one discovers a previously discarded solution, which allocates primary taxing rights to the situs state, secondary rights to the PE state and tertiary rights to the residence state
Citation source
In: British tax review. - London. - (2016),
http://library.link/vocab/creatorName
Sanghavi, D
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • PE
  • situs rule
  • tax treaty
  • immovable property
  • allocation of taxing rights
Label
Income from immovable property - preserving the situs and the permanent establishment principles
Instantiates
Publication
Label
Income from immovable property - preserving the situs and the permanent establishment principles
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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