Capital gains taxation: alienation of immovable property may be taxed in the State where the property is located. Article 13 assigns taxation rights on capital gains: gains from alienation of immovable property situated in a State may be taxed by that State; gains from movable property 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; shares or interests deriving predominantly from immovable property may be taxed in the State where that property is situated; other share disposals may be taxed in the company's State of residence; all other gains remain 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 taxation: alienation of immovable property may be taxed in the State where the property is located.
Article 13 assigns taxation rights on capital gains: gains from alienation of immovable property situated in a State may be taxed by that State; gains from movable property 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; shares or interests deriving predominantly from immovable property may be taxed in the State where that property is situated; other share disposals may be taxed in the company's State of residence; all other gains remain taxable only in the alienator's State of residence.
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