Capital taxation: property and business assets may be taxed in the State where they are situated or attributable. Capital taxation allocates taxing rights by asset type and location: immovable property may be taxed in the State where situated; movable property forming part of a permanent establishment or pertaining to a fixed base for independent personal services may be taxed in the State where that establishment or base is located; ships and aircraft in international traffic and related movable property are taxable only in the State of enterprise residence; all other elements of a resident's capital are 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: property and business assets may be taxed in the State where they are situated or attributable.
Capital taxation allocates taxing rights by asset type and location: immovable property may be taxed in the State where situated; movable property forming part of a permanent establishment or pertaining to a fixed base for independent personal services may be taxed in the State where that establishment or base is located; ships and aircraft in international traffic and related movable property are taxable only in the State of enterprise residence; all other elements of a resident's capital are taxable only in the State of residence.
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