Article 6 OECD-MA: Income from immovable property

Article 6 of the OECD Model Tax Convention governs the right to tax income from immovable property. In their article, Hardy Fischer and Elisabeth Märker deal with the details of the provision as well as the interaction between the implementation in German double taxation treaties and national tax law. In the new edition, the previous commentary has been updated, particularly with regard to more recent case law. Legal changes in connection with the German Partnership Law Modernization Act (“MoPeG”), which came into force on 1.1.2024, have also been incorporated.