Capital gains: alienation of immovable or PE-related property may be taxed in State where property or PE is located Article 14 permits taxation by the State where immovable property is situated of gains from its alienation, allows the State where a permanent establishment or fixed base is located to tax gains from disposal of movable property forming part of that business or fixed base (including disposal of the permanent establishment or fixed base), confines taxation of gains from ships or aircraft in international traffic to the alienator's State of residence, permits source-State taxation of gains on shares principally consisting of immovable property, and reserves all other gains to 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: alienation of immovable or PE-related property may be taxed in State where property or PE is located
Article 14 permits taxation by the State where immovable property is situated of gains from its alienation, allows the State where a permanent establishment or fixed base is located to tax gains from disposal of movable property forming part of that business or fixed base (including disposal of the permanent establishment or fixed base), confines taxation of gains from ships or aircraft in international traffic to the alienator's State of residence, permits source-State taxation of gains on shares principally consisting of immovable property, and reserves all other gains to the alienator's State of residence.
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