Capital gains: disposals of immovable property and certain share interests can be taxed where the property or company is located. Capital gains rules allocate taxation: gains from immovable property are taxable in the State where the property is situated; gains from movable property of a permanent establishment or fixed base, including disposals of that establishment or base, may be taxed where that establishment or base is located; sales of ships or aircraft in international traffic are taxable only in the alienator's State of residence; transfers of interests deriving their value principally from immovable property and disposals of substantial shareholdings may be taxed in the State where the immovable property or company 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: disposals of immovable property and certain share interests can be taxed where the property or company is located.
Capital gains rules allocate taxation: gains from immovable property are taxable in the State where the property is situated; gains from movable property of a permanent establishment or fixed base, including disposals of that establishment or base, may be taxed where that establishment or base is located; sales of ships or aircraft in international traffic are taxable only in the alienator's State of residence; transfers of interests deriving their value principally from immovable property and disposals of substantial shareholdings may be taxed in the State where the immovable property or company is situated; other gains are taxable only in the alienator's State of residence.
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