Capital taxation: location-based taxing rights for immovable property, permanent establishments, international traffic and resident shares. Capital represented by immovable property may be taxed in the State where the property is situated. 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 permanent establishment or fixed base is located. Ships and aircraft operated in international traffic, and related movable property, are taxable only in the State of residence of the enterprise. Shares of companies whose property is principally immovable may be taxed where the immovables are situated; shares representing a qualifying participation in a resident company may be taxed in the resident State. All other capital is 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: location-based taxing rights for immovable property, permanent establishments, international traffic and resident shares.
Capital represented by immovable property may be taxed in the State where the property is situated. 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 permanent establishment or fixed base is located. Ships and aircraft operated in international traffic, and related movable property, are taxable only in the State of residence of the enterprise. Shares of companies whose property is principally immovable may be taxed where the immovables are situated; shares representing a qualifying participation in a resident company may be taxed in the resident State. All other capital is taxable only in the State of residence.
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