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          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.

          <h1>Capital gains taxation: source-based rules allocate tax to situs, permanent establishment, place of management, or residence.</h1> Article 13 prescribes that capital gains from alienation of immovable property are taxable in the State where the property is situated; gains from movable property forming part of a permanent establishment or pertaining to a fixed base are taxable in the State of that establishment or base; gains from ships and aircraft in international traffic are taxable in the State of the enterprise's place of effective management; shares of a resident company may be taxed in the company's State of residence; other gains are taxable only in the alienator's State of residence. 'Alienation' is defined broadly.

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