Capital gains taxation: allocation rules assign taxing rights for immovable property, corporate shares, permanent establishments, and aircraft. Article 14 allocates taxing rights over capital gains under the Finland DTAA: immovable property gains are taxable where the property is located; gains ... Summary
Capital gains taxation: allocation rules assign taxing rights for immovable property, corporate shares, permanent establishments, and aircraft.
Article 14 allocates taxing rights over capital gains under the Finland DTAA: immovable property gains are taxable where the property is located; gains from shares or corporate rights may be taxed where the company is registered; gains from movable property of a permanent establishment or fixed base, including their alienation, may be taxed where that establishment or base is situated; and gains from ships or aircraft in international traffic are taxable only in the State of the enterprise's place of effective management.
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