Capital gains rules: international ships and aircraft taxed in owner state; shares tied to real property taxable in property state. Gains from alienation of ships or aircraft operated in international traffic and related movable property are taxable only in the enterprise's Contracting State, while other capital gains may be taxed by both Contracting States; additionally, gains from alienation of shares or comparable interests that principally derive their value from immovable property situated in the other Contracting State may be taxed by that other State.
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 rules: international ships and aircraft taxed in owner state; shares tied to real property taxable in property state.
Gains from alienation of ships or aircraft operated in international traffic and related movable property are taxable only in the enterprise's Contracting State, while other capital gains may be taxed by both Contracting States; additionally, gains from alienation of shares or comparable interests that principally derive their value from immovable property situated in the other Contracting State may be taxed by that other State.
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