Recently, the UN Committee of Experts in International Cooperation in Tax Matters discussed an amendment of the definition of immovable property under Art 6(2) UN Model Convention. As the Committee considered the approach for the reference to domestic law in Art 3(2) UN Model Convention instructive, the phrase “unless the context otherwise requires" might be inserted into Art 6(2) UN Model Convention. Michael Lang analyzes the questions arising from this possible amendment.
