Capital gains allocation: property located in another Contracting State may be taxed where the property is situated. Gains from alienation of immovable property are taxable in the State where the property is situated; gains from movable property of a permanent establishment or fixed base may be taxed in the State where that establishment or base is located; gains from disposal of ships or aircraft used in international traffic are taxable only in the enterprise's State of residence; gains from sale of shares are taxable in the company's State of residence; 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: property located in another Contracting State may be taxed where the property is situated.
Gains from alienation of immovable property are taxable in the State where the property is situated; gains from movable property of a permanent establishment or fixed base may be taxed in the State where that establishment or base is located; gains from disposal of ships or aircraft used in international traffic are taxable only in the enterprise's State of residence; gains from sale of shares are taxable in the company's State of residence; other gains are taxable only in the alienator's State of residence.
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