Taxation of immovable property: situs-based and category-specific taxing rights determine which State may tax capital. Allocation of taxing rights distinguishes property by category and situs: immovable property is taxable where situated; movable property forming part of a permanent establishment or pertaining to a fixed base for independent services may be taxed where that establishment or base is located; ships, aircraft and related equipment in international traffic are taxable only in the owner's State of residence; all other capital elements are taxable only in the resident's State.
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 immovable property: situs-based and category-specific taxing rights determine which State may tax capital.
Allocation of taxing rights distinguishes property by category and situs: immovable property is taxable where situated; movable property forming part of a permanent establishment or pertaining to a fixed base for independent services may be taxed where that establishment or base is located; ships, aircraft and related equipment in international traffic are taxable only in the owner's State of residence; all other capital elements are taxable only in the resident's State.
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