Capital taxation: situs-based taxing rights for immovable property, PE business assets, and place-of-effective-management rule for ships and aircraft. Allocation of taxing rights over a resident's capital under the Cyprus DTAA is situs-based: immovable property may be taxed where situated; business movable property of a permanent establishment and movable property of a fixed base used for independent personal services may be taxed where the establishment or base is located; ships and aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; 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: situs-based taxing rights for immovable property, PE business assets, and place-of-effective-management rule for ships and aircraft.
Allocation of taxing rights over a resident's capital under the Cyprus DTAA is situs-based: immovable property may be taxed where situated; business movable property of a permanent establishment and movable property of a fixed base used for independent personal services may be taxed where the establishment or base is located; ships and aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; all other capital is taxable only in the State of residence.
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