Taxation of capital: source state taxation applies to immovable property, PE assets, and international ships and aircraft. Allocation of taxing rights depends on asset category and location: immovable property situated in the other State may be taxed there; movable property forming part of a permanent establishment's business property or pertaining to a fixed base for independent services in the other State may be taxed there; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise; all other capital elements are taxable only in the 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.
Taxation of capital: source state taxation applies to immovable property, PE assets, and international ships and aircraft.
Allocation of taxing rights depends on asset category and location: immovable property situated in the other State may be taxed there; movable property forming part of a permanent establishment's business property or pertaining to a fixed base for independent services in the other State may be taxed there; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise; all other capital elements are taxable only in the State of residence.
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