Capital gains taxation: source Contracting Party may tax gains from immovable property and share disposals tied to immovable assets. Capital gains from alienation of immovable property situated in the other Contracting Party may be taxed by that Party; gains from disposals of movable property forming part of a permanent establishment or of a fixed base used for independent services may likewise be taxed where the permanent establishment or fixed base is located; ships or aircraft in international traffic are taxable only in the resident Contracting Party. Share disposals deriving substantial asset value from immovable property may be taxed in the other Party, other share disposals in the resident Party, and other gains under domestic law; benefits are denied if a main purpose is to obtain Article advantages.
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 Contracting Party may tax gains from immovable property and share disposals tied to immovable assets.
Capital gains from alienation of immovable property situated in the other Contracting Party may be taxed by that Party; gains from disposals of movable property forming part of a permanent establishment or of a fixed base used for independent services may likewise be taxed where the permanent establishment or fixed base is located; ships or aircraft in international traffic are taxable only in the resident Contracting Party. Share disposals deriving substantial asset value from immovable property may be taxed in the other Party, other share disposals in the resident Party, and other gains under domestic law; benefits are denied if a main purpose is to obtain Article advantages.
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