Capital gains taxation: immovable property gains may be taxed by the State where the property is situated. Gains from alienation of immovable property situated in one Contracting State may be taxed in that State. Gains from alienation of movable property forming part of the business property of a permanent establishment, or of movable property pertaining to a fixed base used for independent personal services, and gains from alienation of such permanent establishment or fixed base, may be taxed in the State where they are situated. Gains from ships or aircraft in international traffic are taxable only in the resident State; 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 taxation: immovable property gains may be taxed by the State where the property is situated.
Gains from alienation of immovable property situated in one Contracting State may be taxed in that State. Gains from alienation of movable property forming part of the business property of a permanent establishment, or of movable property pertaining to a fixed base used for independent personal services, and gains from alienation of such permanent establishment or fixed base, may be taxed in the State where they are situated. Gains from ships or aircraft in international traffic are taxable only in the resident State; other gains are taxable only in the alienator's State of residence.
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