Capital gains taxation: asset situs governs exclusive taxing rights, with shares and international ships or aircraft treated specially. Capital gains are taxable only in the Contracting State where the capital asset is situated at the time of sale, exchange or transfer; shares are deemed situated in the State of the company's incorporation; capital gains from ships or aircraft operated in international traffic are taxable only in the Contracting State of the enterprise operating them.
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: asset situs governs exclusive taxing rights, with shares and international ships or aircraft treated specially.
Capital gains are taxable only in the Contracting State where the capital asset is situated at the time of sale, exchange or transfer; shares are deemed situated in the State of the company's incorporation; capital gains from ships or aircraft operated in international traffic are taxable only in the Contracting State of the enterprise operating them.
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