Capital gains taxation under the DTAA allocates source rights for immovable and PE-linked assets, residence rule for other disposals. The Sweden DTAA allocates capital gains taxation: immovable property and disposals linked to a permanent establishment or fixed base may be taxed in the State where those assets are located; ships and aircraft in international traffic are taxable only in the resident State (with a specified consortium apportionment); disposals of shares chiefly representing immovable property may be taxed in the State where the immovable property is situated; other gains are taxable in the alienator's State of residence unless not taxed there, and a four year rule allows the former residence State to tax certain gains following an individual's emigration.
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 under the DTAA allocates source rights for immovable and PE-linked assets, residence rule for other disposals.
The Sweden DTAA allocates capital gains taxation: immovable property and disposals linked to a permanent establishment or fixed base may be taxed in the State where those assets are located; ships and aircraft in international traffic are taxable only in the resident State (with a specified consortium apportionment); disposals of shares chiefly representing immovable property may be taxed in the State where the immovable property is situated; other gains are taxable in the alienator's State of residence unless not taxed there, and a four year rule allows the former residence State to tax certain gains following an individual's emigration.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
