Capital gains taxation: treaty allows source state to tax gains from alienation of immovable property and shares tied to it. Gains from alienation of immovable property situated in a Contracting State, or shares whose value is mainly from such property, may be taxed by the State where the property is located. Gains tied to movable property of a permanent establishment or to a fixed base may be taxed in the State of that establishment or base; by contrast, gains from international ships, aircraft, specified containers, and other property generally remain 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: treaty allows source state to tax gains from alienation of immovable property and shares tied to it.
Gains from alienation of immovable property situated in a Contracting State, or shares whose value is mainly from such property, may be taxed by the State where the property is located. Gains tied to movable property of a permanent establishment or to a fixed base may be taxed in the State of that establishment or base; by contrast, gains from international ships, aircraft, specified containers, and other property generally remain taxable only in the alienator's State of residence.
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