Taxation of gains from alienation: situs-based taxation for immovable property and residence-based taxation for other disposals. Gains from alienation of immovable property and of shares in companies whose assets are principally immovable may be taxed in the State where the property ... Summary
Taxation of gains from alienation: situs-based taxation for immovable property and residence-based taxation for other disposals.
Gains from alienation of immovable property and of shares in companies whose assets are principally immovable may be taxed in the State where the property or principal assets are situated. Movable property forming part of a permanent establishment or fixed base may be taxed in the State where that establishment or base exists; ships and aircraft in international traffic and their operational movable property are taxable only in the alienator's State of residence. Other shares in resident companies and other property gains are taxable only in the alienator's State of residence.
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