Capital gains taxation: source territory may tax disposals of immovable property and certain business assets abroad. Capital gains taxation allocates taxing rights: gains from immovable property situated in a territory may be taxed there; gains from movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services, including disposals of that establishment or base, may be taxed in the territory where they are situated; gains from ships or aircraft in international traffic are taxable only in the alienator's residence territory; shares deriving over fifty percent of their value from immovable property situated in the other territory may be taxed in that other territory; other share disposals may be taxed in the company's residence territory; all other gains are taxable only in the alienator's residence territory.
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: source territory may tax disposals of immovable property and certain business assets abroad.
Capital gains taxation allocates taxing rights: gains from immovable property situated in a territory may be taxed there; gains from movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services, including disposals of that establishment or base, may be taxed in the territory where they are situated; gains from ships or aircraft in international traffic are taxable only in the alienator's residence territory; shares deriving over fifty percent of their value from immovable property situated in the other territory may be taxed in that other territory; other share disposals may be taxed in the company's residence territory; all other gains are taxable only in the alienator's residence territory.
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