Carlo Garbarino, Full Professor of International Taxation, Department of Legal Studies, Bocconi University and Director of Osservatorio Fiscale, SDA Bocconi School of Management, Milano, Italy

• Contents: 1. Scope of the Treaties 2. Residence for Treaty Purposes 3. Definition of Permanent Establishment 4. Business Profits and Associated Enterprises 5. Income from Immovable Property, Capital Gains, and Capital 6. Income from Equity and from Debt 7. Royalties 8. Income from Employment, Directors’ Fees, and Students 9. Entertainers and Sportspersons 10. Pensions and Government Service 11. Other Income and International Transport 12. Methods for Elimination of Double Taxation 13. Non-Discrimination 14. Mutual Agreement Procedure 15. Exchange of Information and Assistance in Collection Index

Carlo Garbarino, Full Professor of International Taxation, Department of Legal Studies, Bocconi University and Director of Osservatorio Fiscale, SDA Bocconi School of Management, Milano, Italy

• Contents: 1. Scope of the Treaties 2. Residence for Treaty Purposes 3. Definition of Permanent Establishment 4. Business Profits and Associated Enterprises 5. Income from Immovable Property, Capital Gains, and Capital 6. Income from Equity and from Debt 7. Royalties 8. Income from Employment, Directors’ Fees, and Students 9. Entertainers and Sportspersons 10. Pensions and Government Service 11. Other Income and International Transport 12. Methods for Elimination of Double Taxation 13. Non-Discrimination 14. Mutual Agreement Procedure 15. Exchange of Information and Assistance in Collection Index

Carlo Garbarino, Full Professor of International Taxation, Department of Legal Studies, Bocconi University and Director of Osservatorio Fiscale, SDA Bocconi School of Management, Milano, Italy

• Contents: 1. Scope of the Treaties 2. Residence for Treaty Purposes 3. Definition of Permanent Establishment 4. Business Profits and Associated Enterprises 5. Income from Immovable Property, Capital Gains, and Capital 6. Income from Equity and from Debt 7. Royalties 8. Income from Employment, Directors’ Fees, and Students 9. Entertainers and Sportspersons 10. Pensions and Government Service 11. Other Income and International Transport 12. Methods for Elimination of Double Taxation 13. Non-Discrimination 14. Mutual Agreement Procedure 15. Exchange of Information and Assistance in Collection Index