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The relationship between the taxation of business profits and income from immovable property under tax treaties electrónico Savvas Kostikidis

By: Kostikidis, Savvas.
Material type: ArticleArticleSubject(s): EMPRESAS | BENEFICIOS | PROPIEDAD INMOBILIARIA | RENTA | IMPUESTOS | MODELO DE CONVENIO OCDE | INTERPRETACION In: Bulletin for International Taxation v. 76, n. 3, 2022, p. 141-157Summary: 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.
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Resumen.

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.

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