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          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.

          <h1>Capital gains taxation: immovable property and permanent establishment assets taxable where situated, with specific share disposal rules.</h1> Article 13 allocates taxation of capital gains: immovable property gains are taxable where the property is situated; gains of movable property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is located; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; specific rules govern taxation of shares depending on acquisition date, with a transitional tax-rate limitation for an interim period; all other gains are taxable only in the alienator's State of residence.

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