Capital taxation under tax treaty allocates property-situated capital to source state and other capital to residence. Capital represented by immovable property is taxable in the State where situated; movable property forming part of a permanent establishment is taxable in the State of that permanent establishment; ships and aircraft in international traffic and related movable property are taxable in the State of the enterprise's place of effective management; all other elements of capital of a resident are taxable only in the resident 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.
Capital taxation under tax treaty allocates property-situated capital to source state and other capital to residence.
Capital represented by immovable property is taxable in the State where situated; movable property forming part of a permanent establishment is taxable in the State of that permanent establishment; ships and aircraft in international traffic and related movable property are taxable in the State of the enterprise's place of effective management; all other elements of capital of a resident are taxable only in the resident State.
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