Capital taxation rules allocate taxing rights between source state for property-linked capital and resident state for other capital. Article 23 provides that capital from immovable property situated in the other Contracting State may be taxed there; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where that establishment or fixed base is situated; capital represented by ships and aircraft operated in international traffic and their operational movable property shall be taxable only in that State; all other capital of a resident shall be taxable only in the resident State.
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 rules allocate taxing rights between source state for property-linked capital and resident state for other capital.
Article 23 provides that capital from immovable property situated in the other Contracting State may be taxed there; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where that establishment or fixed base is situated; capital represented by ships and aircraft operated in international traffic and their operational movable property shall be taxable only in that State; all other capital of a resident shall be taxable only in the resident State.
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