A person who is a resident in Spain owns a property in France and rents it to a person who is a resident of a third State, named Omnia. The tenant pays the rent from an Omnian bank account to the Spanish bank account of the Spanish landlord.

Spanish (Landlord)

Omnia (Tenant)

France (Property)

The local applicable rules are as follows: Spain provides for the world-wide taxation of individuals resident in Spain; France provides for the taxation of rental income deriving from property located in FranceOmnia provides for the taxation of rental income when the payment is made by an Omnian

resident.

What would be the applicable regime if the treaty between Italy and France and the treaty between Italy and Omnia were identical to the OECD Model Tax Convention?