Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...

The past decade has witnessed a significant increase in cross-border capital flows and a pronounced shift in their composition towards portfolio investment, with much of the capital under management by mutual funds or "collective investment institutions" resident in OECD countries, as well as in...