Capital gains DTAA: alienation of ships or aircraft in international traffic taxable only in that State; others taxable in both. Article 13 establishes that gains from the alienation of ships or aircraft operated in international traffic, and movable property pertaining to their operation, are taxable only in that State; gains from alienation of any other property may be taxed in both Contracting States.
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 DTAA: alienation of ships or aircraft in international traffic taxable only in that State; others taxable in both.
Article 13 establishes that gains from the alienation of ships or aircraft operated in international traffic, and movable property pertaining to their operation, are taxable only in that State; gains from alienation of any other property may be taxed in both Contracting States.
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