Taxation of capital: immovable and PE-related capital taxable in source state, while ships and aircraft capital taxed only in residence. Capital taxation allocates taxing rights by asset type: immovable property situated in a Contracting State may be taxed there; movable property forming part of business property of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where that establishment or fixed base is located; capital represented by ships or aircraft in international traffic and related movable property is taxable only in the State of residence. The Model leaves taxation of other elements of capital either to the State of residence or to bilateral negotiation.
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 and PE-related capital taxable in source state, while ships and aircraft capital taxed only in residence.
Capital taxation allocates taxing rights by asset type: immovable property situated in a Contracting State may be taxed there; movable property forming part of business property of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where that establishment or fixed base is located; capital represented by ships or aircraft in international traffic and related movable property is taxable only in the State of residence. The Model leaves taxation of other elements of capital either to the State of residence or to bilateral negotiation.
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