Taxation of capital: immovable and business-related movable property taxable in source state; other capital taxable only in residence. Capital from immovable property located in the other Contracting State and movable property forming part of a permanent establishment or fixed base may be taxed in that other State; ships, aircraft and motor vehicles engaged in international traffic and related movable property are taxable only in the enterprise's State of residence, and all other elements of a resident's capital are taxable only in the resident State.
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: immovable and business-related movable property taxable in source state; other capital taxable only in residence.
Capital from immovable property located in the other Contracting State and movable property forming part of a permanent establishment or fixed base may be taxed in that other State; ships, aircraft and motor vehicles engaged in international traffic and related movable property are taxable only in the enterprise's State of residence, and all other elements of a resident's capital are taxable only in the resident State.
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