Taxation of capital: situs rules for immovable property and PE-based movable property; ships taxed in residence state. Article 24 allocates taxing rights over capital: immovable property is taxable where situated; movable property forming part of a permanent establishment or pertaining to a fixed base may be taxed where that establishment or base is located; ships and aircraft operated in international traffic and related movable property are taxable only in the enterprise's State of residence; all other capital of a resident 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.
Taxation of capital: situs rules for immovable property and PE-based movable property; ships taxed in residence state.
Article 24 allocates taxing rights over capital: immovable property is taxable where situated; movable property forming part of a permanent establishment or pertaining to a fixed base may be taxed where that establishment or base is located; ships and aircraft operated in international traffic and related movable property are taxable only in the enterprise's State of residence; all other capital of a resident is taxable only in the State of residence.
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