Taxation of capital: treaty allocates taxing rights by asset type between source and resident states. Allocation of taxing rights over capital depends on asset type and location: immovable property may be taxed in the State where situated; movable property of a permanent establishment or fixed base may be taxed in the State of that establishment or base; ships and aircraft in international traffic and their operating 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: treaty allocates taxing rights by asset type between source and resident states.
Allocation of taxing rights over capital depends on asset type and location: immovable property may be taxed in the State where situated; movable property of a permanent establishment or fixed base may be taxed in the State of that establishment or base; ships and aircraft in international traffic and their operating 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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