The Relationship between the Taxation of Business Profits and Income from Immovable Property under Tax Treaties
Journal
International; OECD
Bulletin for International Taxation 2022 (Volume 76), No. 3
This article examines the relationship between the provisions in the OECD Model on income from immovable property and on business profits, establishes the overlaps, demonstrates how these overlaps were solved by the predecessors of the OECD and domestic courts – thereby leading to qualification conflicts – and discusses how this situation is currently resolved.