Capital gains allocation: source-state taxation for immovable property and business-establishment disposals; other property taxed in taxpayer's residence. The DTAA allocates capital gains taxation by asset type: immovable property located in the other Contracting State may be taxed there; gains from movable ... Summary
Capital gains allocation: source-state taxation for immovable property and business-establishment disposals; other property taxed in taxpayer's residence.
The DTAA allocates capital gains taxation by asset type: immovable property located in the other Contracting State may be taxed there; gains from movable property of a permanent establishment or fixed base in the other State may be taxed in that State; gains from ships or aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; and other capital gains are taxable only in the alienator's State of residence.
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