Tax residency and source rules: residence state may tax property and capital gains, warehouses may constitute a permanent establishment. The Protocol specifies that the Convention applies when the income arises; excludes penalties or default amounts from the definition of tax; deems warehouses providing storage for others to constitute a permanent establishment; accords the residence State the right to tax income from property and capital gains; ties domestic law references to a specified provision with non less favourable conditions; permits each State to apply its own deductibility and burden of proof procedures under Article 24 and to tax a non resident permanent establishment at a higher rate subject to a limited excess; and requires protection of supplied personal data.
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.
Tax residency and source rules: residence state may tax property and capital gains, warehouses may constitute a permanent establishment.
The Protocol specifies that the Convention applies when the income arises; excludes penalties or default amounts from the definition of tax; deems warehouses providing storage for others to constitute a permanent establishment; accords the residence State the right to tax income from property and capital gains; ties domestic law references to a specified provision with non less favourable conditions; permits each State to apply its own deductibility and burden of proof procedures under Article 24 and to tax a non resident permanent establishment at a higher rate subject to a limited excess; and requires protection of supplied personal data.
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