Capital gains taxation under DTAA: source state may tax gains from immovable property and certain company shares. Capital gains under the DTAA allocate taxing rights by property type and location: gains from alienation of immovable property situated in the source State and gains from movable property of a permanent establishment or fixed base located in the source State may be taxed in that State; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; gains from shares principally representing immovable property may be taxed in the State where the immovable property is located, whereas other share gains and all other unspecified gains are taxable only in the alienator's State of residence.
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 gains taxation under DTAA: source state may tax gains from immovable property and certain company shares.
Capital gains under the DTAA allocate taxing rights by property type and location: gains from alienation of immovable property situated in the source State and gains from movable property of a permanent establishment or fixed base located in the source State may be taxed in that State; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; gains from shares principally representing immovable property may be taxed in the State where the immovable property is located, whereas other share gains and all other unspecified gains are taxable only in the alienator's State of residence.
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