Capital taxation: immovable and PE-linked movable property taxable in the state where situated, other capital taxed in state of residence. Capital taxation assigns taxing rights by asset category: immovable property situated in the other State may be taxed where located; movable property forming part of the business property of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where the permanent establishment or fixed base exists; ships and aircraft in international traffic (and associated movable property) are taxable only in the State of the enterprise's place of effective management; remaining capital is 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.
Capital taxation: immovable and PE-linked movable property taxable in the state where situated, other capital taxed in state of residence.
Capital taxation assigns taxing rights by asset category: immovable property situated in the other State may be taxed where located; movable property forming part of the business property of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where the permanent establishment or fixed base exists; ships and aircraft in international traffic (and associated movable property) are taxable only in the State of the enterprise's place of effective management; remaining capital is taxable only in the State of residence.
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