Taxation of capital: taxing rights allocated by asset type and location, with special rules for immovables and international vessels. Allocation of taxation rights over capital depends on asset type and location: immovable property and rights treated as immovable may be taxed where situated; shares of companies principally holding immovables may be taxed in the State where the immovables are located (excluding immovables used in industrial or commercial operation); movable property of a permanent establishment or fixed base may be taxed where that establishment or base is situated; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise's place of effective management; 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.
Taxation of capital: taxing rights allocated by asset type and location, with special rules for immovables and international vessels.
Allocation of taxation rights over capital depends on asset type and location: immovable property and rights treated as immovable may be taxed where situated; shares of companies principally holding immovables may be taxed in the State where the immovables are located (excluding immovables used in industrial or commercial operation); movable property of a permanent establishment or fixed base may be taxed where that establishment or base is situated; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise's place of effective management; other capital is taxable only in the State of residence.
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