Capital gains allocation: treaty permits source-state taxation for immovable property and business-related movable property linked to establishment. The treaty permits the source State to tax gains from alienation of immovable property situated there and gains from disposal of movable property forming part of the business property of a permanent establishment or attributable to a fixed base in that State; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; shares principally representing immovable property may be taxed in the State where the immovable property is situated, while other share disposals and other gains are 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 allocation: treaty permits source-state taxation for immovable property and business-related movable property linked to establishment.
The treaty permits the source State to tax gains from alienation of immovable property situated there and gains from disposal of movable property forming part of the business property of a permanent establishment or attributable to a fixed base in that State; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; shares principally representing immovable property may be taxed in the State where the immovable property is situated, while other share disposals and other gains are taxable only in the alienator's State of residence.
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