Capital gains taxation: immovable property taxed where located; residence governs other unspecified property gains. Capital gains from alienation of immovable property situated in a Contracting State may be taxed in that State. Gains from movable property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is located. Alienation of ships or aircraft in international traffic and related movable property is taxable only in the alienator's State of residence. Shares deriving principally from immovable property may be taxed in the State where that property is situated; other resident-company shares may be taxed in the company's State of residence. Other property gains are taxable only in the alienator's 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.
Capital gains taxation: immovable property taxed where located; residence governs other unspecified property gains.
Capital gains from alienation of immovable property situated in a Contracting State may be taxed in that State. Gains from movable property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is located. Alienation of ships or aircraft in international traffic and related movable property is taxable only in the alienator's State of residence. Shares deriving principally from immovable property may be taxed in the State where that property is situated; other resident-company shares may be taxed in the company's State of residence. Other property gains are taxable only in the alienator's State of residence.
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