Simontacchi Taxation of Capital Gains under the OECD Model Convention

with special regard to immovable property
Erscheinungsjahr 2007
ISBN: 978-90-411-5580-1
Verlag: Wolters Kluwer
Format: PDF
Kopierschutz: Adobe DRM (»Systemvoraussetzungen)

E-Book, Englisch, 436 Seiten, Web PDF

Increasing globalization and the related cross-border flows of capital
resources has only increased interest in the taxation of transnational capital
gains among practitioners and scholars. This is particularly true as it
relates to investments in immovable property. As a consequence, Article 13 of
the OECD Model Convention - covering capital gains - has emerged as one of the
document’s key provisions. Despite this, international tax literature has
devoted little attention to the systematic analysis of capital gains in
relation to tax treaties. Stefano Simontacchi's thorough and thoughtful
examination of the ramifications of Article 13 addresses this “need to know”
in a meaningful - and readily actionable - fashion.

Based on in-depth historical research, the book pays particular attention to
the definition of capital gains falling within the scope of Article 13. It
also thoroughly analyses the treaty regime applicable to gains derived from
the alienation of both immovable property and shares of immovable property
companies.

International tax professionals will quickly recognize Stefano Simontacchi’s
book as an indispensable and highly accessible guide to an area of practice
that continues to grow in scope and importance.

Autoren/Hrsg.

Simontacchi, Stefano

Fachgebiete

• Rechtswissenschaften Steuerrecht