Taxation of capital: situs rules permit taxing immovable property and permanent establishment assets; other capital taxed at residence. Capital represented by immovable property situated in the other Contracting State may be taxed in that State. Movable property forming part of the business property of a permanent establishment may be taxed in the State where the permanent establishment is located. Capital of an enterprise operating ships or aircraft in international traffic, represented by such vessels and by movable property pertaining to their operation, is taxable only in the State of residence. All other elements of capital of a resident are 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: situs rules permit taxing immovable property and permanent establishment assets; other capital taxed at residence.
Capital represented by immovable property situated in the other Contracting State may be taxed in that State. Movable property forming part of the business property of a permanent establishment may be taxed in the State where the permanent establishment is located. Capital of an enterprise operating ships or aircraft in international traffic, represented by such vessels and by movable property pertaining to their operation, is taxable only in the State of residence. All other elements of capital of a resident are taxable only in the State of residence.
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