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...

This chapter offers the first global taxonomy of treaty dispute patterns emerging in the almost first 100 years of the international tax regime (ITR). The time and space dimensions of the taxonomy are as follows. The time dimension covers the era which ran from 1923 — when four economists...

This chapter offers the first global quantitative analysis of tax treaty disputes emerging in the almost first 100 years of the international tax regime (ITR). The time and space dimensions of the analysis are as follows. The time dimension covers the era that ran from 1923 — when four...

In 2013, the Organization for Economic Cooperation and Development (OECD) launched its base erosion and profit shifting (BEPS) project to inhibit aggressive international tax planning. Action 1 of the BEPS project requires the OECD to identify the main challenges that the digital economy poses...