Capital taxation rules: immovable property taxed where located; most other capital taxed only in resident state. Capital represented by immovable property is taxable in the State where situated (see Article 6). Movable property forming part of a permanent establishment's business property, or movable property pertaining to a fixed base for independent personal services, may be taxed in the State of that establishment or base. Ships and aircraft operated in international traffic, and related movable property, are taxable only in the State of the enterprise's residence. All other elements of a resident's capital are taxable only in the resident State.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Capital taxation rules: immovable property taxed where located; most other capital taxed only in resident state.
Capital represented by immovable property is taxable in the State where situated (see Article 6). Movable property forming part of a permanent establishment's business property, or movable property pertaining to a fixed base for independent personal services, may be taxed in the State of that establishment or base. Ships and aircraft operated in international traffic, and related movable property, are taxable only in the State of the enterprise's residence. All other elements of a resident's capital are taxable only in the resident State.
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