Capital gains taxation: treaty allocates source or residence taxing rights by property type under cross-border disposals. Article 14 allocates taxing rights for capital gains under the Norway DTAA by property category: gains from immovable property situated in the other Contracting State are taxable there; gains from movable property forming part of a permanent establishment or fixed base in the other State, including sales of that establishment or base, may be taxed in that State; gains from ships or aircraft in international traffic and related equipment are taxable only in the alienator's State of residence; disposals of shares whose value derives principally from immovable property may be taxed where the property is situated; other share disposals and property not otherwise covered are taxable only in the alienator's 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 gains taxation: treaty allocates source or residence taxing rights by property type under cross-border disposals.
Article 14 allocates taxing rights for capital gains under the Norway DTAA by property category: gains from immovable property situated in the other Contracting State are taxable there; gains from movable property forming part of a permanent establishment or fixed base in the other State, including sales of that establishment or base, may be taxed in that State; gains from ships or aircraft in international traffic and related equipment are taxable only in the alienator's State of residence; disposals of shares whose value derives principally from immovable property may be taxed where the property is situated; other share disposals and property not otherwise covered are taxable only in the alienator's State of residence.
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