Taxation of capital: immovable and PE-related movable property taxed where located; other capital taxed in resident state. Immovable property of a resident situated in the other Contracting State may be taxed where situated; movable property forming part of a permanent establishment's business property or pertaining to a fixed base for independent services may be taxed where that permanent establishment or fixed base is located; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise's place of effective management; all other capital is taxable only in the resident State.
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Provisions expressly mentioned in the judgment/order text.
Taxation of capital: immovable and PE-related movable property taxed where located; other capital taxed in resident state.
Immovable property of a resident situated in the other Contracting State may be taxed where situated; movable property forming part of a permanent establishment's business property or pertaining to a fixed base for independent services may be taxed where that permanent establishment or fixed base is located; ships and aircraft in international traffic and related movable property are taxable only in the State of the enterprise's place of effective management; all other capital is taxable only in the resident State.
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