The mechanism of the real estate clause: Selected tax issues

Abstract

This article addresses the issue of the real estate clause, which is an important mechanism in counteracting international tax avoidance. The issue in question is analysed both from the perspective of domestic as well as international tax law (with particular emphasis on double taxation treaties and the MLI Convention). In this article, the author focuses on aspects of an effective use of the real estate clause under the Polish law and alternative forms aimed at taxing profits from real property sale in the country of their location.

Keywords

• real estate clause
• tax
• international tax law