Capital taxation by asset type: immovable and PE-linked movable property taxed at source, transport assets taxable at residence. Capital taxation is allocated by asset type and location: immovable property situated in a Contracting State may be taxed in that State; movable property forming part of a permanent establishment's business property or pertaining to a fixed base used for independent personal services may be taxed in the State where that PE or fixed base is located; ships, aircraft in international traffic and inland waterways boats and related movable property are taxable only in the State of residence; all other capital of a resident 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 by asset type: immovable and PE-linked movable property taxed at source, transport assets taxable at residence.
Capital taxation is allocated by asset type and location: immovable property situated in a Contracting State may be taxed in that State; movable property forming part of a permanent establishment's business property or pertaining to a fixed base used for independent personal services may be taxed in the State where that PE or fixed base is located; ships, aircraft in international traffic and inland waterways boats and related movable property are taxable only in the State of residence; all other capital of a resident is taxable only in the State of residence.
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