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of <h1>Capital Assets Taxation Framework Balances International Business Interests and State Revenue Allocation Under DTAA Article 22</h1> This UN Model Double Tax Avoidance Agreement (DTAA) Article 22 addresses capital taxation across contracting states. It specifies taxation rights for immovable property, business-related movable property, and permanent establishment assets. International transportation assets are taxable only in the enterprise's home state. The provision leaves taxation of other capital elements to bilateral negotiations, allowing flexibility in determining precise taxation jurisdiction.
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