Taxation of capital: immovable and business movable property taxed where situated; ships and aircraft taxed at residence. Immovable property situated in the other Contracting State may be taxed where located; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where that establishment or fixed base is situated; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise's residence; other elements of capital may be taxed where situated.
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: immovable and business movable property taxed where situated; ships and aircraft taxed at residence.
Immovable property situated in the other Contracting State may be taxed where located; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where that establishment or fixed base is situated; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise's residence; other elements of capital may be taxed where situated.
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