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Property investment and tax treaties presentation


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 presentation 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:

Author Photo - Richard Vann CTA
Prof Richard Vann CTA
Prof Richard Vann, CTA, is Challis Professor of Law at the University of Sydney and a Consultant at Greenwoods & Herbert Smith Freehills. He has also taught at NYU Law School, Harvard Law School and the University of London. He has held many government consultancies in Australia, including the Review of Business Taxation (1998•1999), the Review of International Taxation (2002•2003) and the Australian Taxation Office Public Rulings Panels on international and indirect taxation (1995•2007). Most recently, he has been involved in various Board of Taxation work on managed investment trusts and collective investment vehicles, the attribution of profits to permanent establishments and as a member of Treasury’s BEPS Advisory Group. Richard is the Editor-in-Chief of the IBFD Global Tax Treaties Commentaries now being progressively published online. Current at 17 March 2016 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.

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Individual sessions

Real property investment in Japan

Author(s):  Max SEVERENS,  Andrew WHITE

Materials from this session:

Taxation of financial arrangements: the impact upon property entities

Author(s):  Scott FARRELL

Materials from this session:

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