Capital taxation rules allocate taxing rights by asset location, covering immovable property, PE movables, and international ships. Article 23 allocates taxing rights over capital by asset type and location: immovable property taxed where situated; movable property forming part of a permanent establishment's business property or pertaining to a fixed base for independent personal services taxed in the State where that establishment or base exists; ships and aircraft operated in international traffic and their operational movables taxable only in the State of the enterprise; all other capital elements taxable only in the resident's 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 allocate taxing rights by asset location, covering immovable property, PE movables, and international ships.
Article 23 allocates taxing rights over capital by asset type and location: immovable property taxed where situated; movable property forming part of a permanent establishment's business property or pertaining to a fixed base for independent personal services taxed in the State where that establishment or base exists; ships and aircraft operated in international traffic and their operational movables taxable only in the State of the enterprise; all other capital elements taxable only in the resident's State.
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