Capital gains taxation: source State may tax gains from alienation of immovable property and business-related assets. Gains from disposal of property are allocated by reference to the property's link with the source State: immovable property situated in the other Contracting State and disposals of movable property forming part of a permanent establishment or fixed base there may be taxed in that State; disposals of ships or aircraft in international traffic are taxable only in the alienator's State of residence; shares or comparable interests whose value principally derives from immovable property may be taxed in the State where the immovable property is situated; other gains are taxable only 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: source State may tax gains from alienation of immovable property and business-related assets.
Gains from disposal of property are allocated by reference to the property's link with the source State: immovable property situated in the other Contracting State and disposals of movable property forming part of a permanent establishment or fixed base there may be taxed in that State; disposals of ships or aircraft in international traffic are taxable only in the alienator's State of residence; shares or comparable interests whose value principally derives from immovable property may be taxed in the State where the immovable property is situated; other gains are taxable only in the alienator's State of residence.
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