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derived principally from rental income. It distributes most of its income yearly, and in general, does not pay income tax on income derived from its real estate investment and distributed to its unitholders. It normally operates in a specific area of expertise such as residential, retail, office, industrial, hotel and resort REITs, etc. In Europe it is generally organized as a corporation. In Asia, it is a trust and in U.S. and Japan, it can either be trust or corporation. (Nouel, Luis: The Tax Treaty Treatment of REITs The Alternative Provisions Included in the Commentaries on the 2008 OECD Model, European Taxation 2008, S.477-483) (To be continued) (Evelyn Garcia-Cantre is a Senior Manager of Tax of Manabat Sanagustin & Co., CPAs, a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (KPMG International), a Swiss entity. The views and opinions expressed herein are those of the author and do not necessarily represent the views and opinions of KPMG in the Philippines. For comments or inquiries, please email manila@kpmg.com or egarcia-cantre@kpmg.com )