shopping_cart

Your shopping cart is empty

Property investment and tax treaties paper

Member Price: $57.00
Non Member Price: $75.00

DisclaimerThis material is copyright. Apart from any fair dealing for the purposes of private study, research, criticism or review, as permitted under the Copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.

Published on 12 Sep 07 by NEW SOUTH WALES DIVISION, THE TAX INSTITUTE

The growth of REIT regimes worldwide has led the OECD to set up a working group to consider the tax treaty implications of cross border property investment via REITs (and Australian property trusts) and whether any modifications to tax treaty texts are appropriate. It is expected that a draft report will be released for comment by the OECD later this year. This paper considers the treaty issues, in particular:

  • tax treaty impact of different vehicles (corporate REITs and flow-through trusts/partnerships/contracts) used for collective property investment around the world
  • tax treaty impact of different ways of removing income tax at the level of the entity
  • application of current tax treaties to REITs and similar vehicles
  • possible modifications to real property, dividend and capital gains articles of tax treaties to deal with REITs and similar vehicles
  • relief of double taxation problems and tax treaty responses
  • EU tax problems for REIT regimes and their interaction with tax treaties.

Author profile

Prof Richard Vann CTA
Richard is Challis Professor of Law at the University of Sydney and has taught at Harvard and NYU Law Schools and the Universities of Amsterdam, London and Oxford. Richard has worked in the past at the IMF and OECD and held many Government consultancies in Australia and elsewhere. He has been a consultant for specialist tax firm Greenwoods & Herbert Smith Freehills since 1985. Richard specialises in corporate and international taxation on which he has published widely both in Australia and internationally. - Current at 15 June 2022
Click here to expand/collapse more articles by Richard J VANN.

 

This was presented at 5th Annual Property Intensive - An update of local and global property issues .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Real property investment in Japan

Author(s):  Max SEVERENS,  Andrew WHITE

Materials from this session:

Property investment and tax treaties

Author(s):  Richard J VANN

Materials from this session:

Recent international developments

Author(s):  Michael COX,  Christian HOLLE

Materials from this session:

New tax measures for property and infrastructure projects

Author(s):  Paul KING

Materials from this session:

Recent GST developments

Author(s):  Matthew CRIDLAND

Materials from this session:

Stamp duty issues for wholesale property funds

Author(s):  Matthew STUTSEL

Materials from this session:

Taxation of financial arrangements: the impact upon property entities

Author(s):  Scott FARRELL

Materials from this session:

Further details about this event:

 

Copyright Statement