Capital taxation: immovable and PE-related movable property taxed in source state; ships and other capital taxed in resident state. Immovable property capital is taxable in the State where located; movable property forming part of a permanent establishment or pertaining to a fixed base for independent personal services is taxable in the State of that establishment or fixed base. Ships and aircraft operated in international traffic, and movable property used in their operation, are taxable only in the State of the enterprise's residence; all other capital elements of a resident are taxable only in the 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 taxation: immovable and PE-related movable property taxed in source state; ships and other capital taxed in resident state.
Immovable property capital is taxable in the State where located; movable property forming part of a permanent establishment or pertaining to a fixed base for independent personal services is taxable in the State of that establishment or fixed base. Ships and aircraft operated in international traffic, and movable property used in their operation, are taxable only in the State of the enterprise's residence; all other capital elements of a resident are taxable only in the State of residence.
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