Capital taxation allocation: immovable property taxed where located; business movable property, ships, and other capital follow PE and residence rules. Capital represented by immovable property is taxable in the State where situated; movable property forming part of business property of a permanent establishment or pertaining to a fixed base may be taxed in the State where that establishment or base is situated; ships and aircraft in international traffic and their operational movable property are taxable only in the State of the enterprise; all other capital of a resident is 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 allocation: immovable property taxed where located; business movable property, ships, and other capital follow PE and residence rules.
Capital represented by immovable property is taxable in the State where situated; movable property forming part of business property of a permanent establishment or pertaining to a fixed base may be taxed in the State where that establishment or base is situated; ships and aircraft in international traffic and their operational movable property are taxable only in the State of the enterprise; all other capital of a resident is taxable only in the State of residence.
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