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Model Tax Convention on Income and on Capital: Condensed Version 2017

image of Model Tax Convention on Income and on Capital: Condensed Version 2017

This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the articles and commentaries of the Model Tax Convention on Income and Capital as it read on 21 November 2017, but without the historical notes and the background reports that are included in the full version.

The full version of the OECD Model Tax Convention for each edition is published separately. It is available in print, PDF and web formats. The web format includes extensive interlinking, making it easy to link from articles to related commentaries. The web and PDF versions will be available via the OECD iLibrary.

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Commentary on Article 6

Paragraph 1 gives the right to tax income from immovable property to the State of source, that is, the State in which the property producing such income is situated. This is due to the fact that there is always a very close economic connection between the source of this income and the State of source. Although income from agriculture or forestry is included in Article 6, Contracting States are free to agree in their bilateral conventions to treat such income under Article 7. Article 6 deals only with income which a resident of a Contracting State derives from immovable property situated in the other Contracting State. It does not, therefore, apply to income from immovable property situated in the Contracting State of which the recipient is a resident within the meaning of Article 4 or situated in a third State; the provisions of paragraph 1 of Article 21 shall apply to such income.

English

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