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  5. International and European Tax Law (TAX4002)

Exam (elaborations)

IMP schemes (EXAM SCHEMES)
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  • Module
  • International and European Tax Law (TAX4002)
  • Institution
  • Maastricht University (UM)

Worried for the exam? No time to prepare well structured notes to bring with you? No problem. These schemes are intended to provide a step-by-step approach to each and every topic covered. They will enable you to save time and answer comprehensively to all exam questions. They combine: (i) lecture ...

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Document information

  • December 15, 2019
  • 3
  • 2019/2020
  • Exam (elaborations)
  • Unknown

Subjects

  • tax law
  • tax
  • immovable property
  • article 6
  • article 13
  • capital gain
  • article 7
  • business profits
  • permanent establishment
  • exam
  • international and european tax law
  • pe

Written for

  • Maastricht University (UM)
  • Master Fiscaal recht
  • International and European Tax Law (TAX4002)
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Cases involving IMP connected to an enterprise

A. IMP situated in the other contracting state (bilateral situations)
1. IMP of an enterprise (resident) of a contracting state which is NOT attributable to a PE:




 DTC: R-S
o Art. 7 does NOT apply since Art. 7(4) gives precedence to Art. 6
o Source state may tax -> Art. 6
2. IMP of an enterprise (resident) of a contracting state which FORMS a PE in the situs state:




 DTC: R-S
o Art. 7(2) applies. NO need to go to 7(4)!!
o According to the AOA, the IMP will form part of the PE’s assets
o Art. 6 does NOT apply -> the income derived by the PE will fall under Art. 7(2) instead
3. IMP of an enterprise (resident) of a contracting state which is attributable to a PE:




 DTC: R-S
o The income derived from the IMP is attributed to the PE (under the AOA)
 Hence, the IMP forms part of the PE’s assets
o Due to the application of Art. 7(4) + Art. (6)(3) the source state may tax under Art. 6
o Art. 7 does NOT apply
4. IMP of an enterprise (resident) of a contracting state NOT attributable to a PE (in State S):




 DTC: R-S

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