Capital gains taxation: allocation of taxing rights between contracting states for immovable property, business assets, shares and other property. Gains from alienation of immovable property situated in a 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 movable property pertaining to a fixed base for independent personal services, including alienation of the permanent establishment or fixed base, may be taxed in the State where they are situated. Shares deriving principally from immovable property may be taxed in the State with that immovable property; other specified gains are taxable 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: allocation of taxing rights between contracting states for immovable property, business assets, shares and other property.
Gains from alienation of immovable property situated in a 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 movable property pertaining to a fixed base for independent personal services, including alienation of the permanent establishment or fixed base, may be taxed in the State where they are situated. Shares deriving principally from immovable property may be taxed in the State with that immovable property; other specified gains are taxable in the alienator's State of residence.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
