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. Based on in-depth historical research, this 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.
Book containing the draft double taxation convention on income and capital of 1963 and the revised texts of certain articles of the 1963 OECD draft double taxation convention on income and capital and of the commentaries thereon, published in 1972. Furthermore, the four reports on the elimination of double taxation, prepared by the OECD Fiscal Committee between 1958 and 1961, are bound in this volume.
The main purpose of the Convention is to provide a standardised system to deal with problems of international juridical double taxation (the imposition of comparable taxes in two or more States on the same taxpayer in relation to the same subject matter and for identical periods). It comprises of two volumes and includes the full text of the Model Tax Convention as updated on 15 July 2005, together with an introduction, commentary and previous background reports (adopted after the publication of the 1977 Model Double Taxation Convention on Income and Capital and that have resulted in changes to the text of Convention articles or corresponding commentary).