2.2. Article 13(4) OECD Model Convention for the Disposal of Immovable Property-Rich Corporations
Article 13(1) of both the OECD Model Convention and the UN Model Convention stipulates…
The language of Article 13(4) of the current German Model Convention 2013 is identical…
German income tax treaties do not (yet) stipulate the 365-day lookback rule, though…
However, where Germany has agreed on an income tax treaty with provisions allocating…
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