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...

Chinese double tax treaties define the territory of China in a broad sense and prima facie Hong Kong is included within the territory of China. However, the Chinese and Hong Kong authorities, as well as all of China's treaty partners, take the view that Hong Kong is not covered by Chinese tax...

This article examines tax treaty trends in five Central Asian Republics: Kazakhstan, the Kyrgyz Republic, Tajikistan, Turkmenistan and Uzbekistan, following the gaining of their independence after the fall of the Soviet Union in 1991. In particular, it compares the construction of treaties...

The notional purpose of tax treaties is to prevent double taxation and tax evasion. The actual purpose is to reallocate taxing rights between an investor's home jurisdiction (the residence state) and the host jurisdiction (the source state). The effect is to reduce or remove the taxing rights of...