Interaction of Articles 6, 7 and 21 of the 2000 OECD Model Convention

This article considers the treaty regime applicable under an OECD Model-type treaty to income from immovable property derived by a resident of a contracting state in the context of an enterprise. The discussion assumes that the resident carries on his entrepreneurial activity through a permanent establishment in the other contracting state and that the immovable property forms part of that permanent establishment. The article examines the treaty ramifications of the treatment of the income in three situations ? when the immovable property is located (a) in the state in which the permanent establishment is situated, (b) in the state in which the recipient of the income is resident and (c) in a third state.