Taxation of capital: immovable property and PE-linked movable assets taxed where situated; other capital taxed in resident state. Taxation of capital is allocated by asset type and location: capital represented by immovable property or rights therein is taxable where situated; shares of companies whose assets are principally immovable are taxable where that property is located (excluding industrial or commercial property of the company); movable property of a permanent establishment or fixed base may be taxed where that establishment or base is located; ships and aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; all 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: immovable property and PE-linked movable assets taxed where situated; other capital taxed in resident state.
Taxation of capital is allocated by asset type and location: capital represented by immovable property or rights therein is taxable where situated; shares of companies whose assets are principally immovable are taxable where that property is located (excluding industrial or commercial property of the company); movable property of a permanent establishment or fixed base may be taxed where that establishment or base is located; ships and aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; all other capital is taxable only in the State of residence.
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