Capital taxation rules allocate taxing rights to the State where assets or business bases are located, with special airline consortium limits. Article 23 allocates taxing rights over capital: immovable property capital is taxable in the State where situated; movable property within a permanent establishment or pertaining to a fixed base for independent services is taxable in the State of that establishment or fixed base; capital in ships and aircraft engaged in international traffic and related movable property is taxable only in the State of the enterprise operating them; a special proviso confines the Article's application to the share of capital attributable to the Swedish partner of the SAS consortium.
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 rules allocate taxing rights to the State where assets or business bases are located, with special airline consortium limits.
Article 23 allocates taxing rights over capital: immovable property capital is taxable in the State where situated; movable property within a permanent establishment or pertaining to a fixed base for independent services is taxable in the State of that establishment or fixed base; capital in ships and aircraft engaged in international traffic and related movable property is taxable only in the State of the enterprise operating them; a special proviso confines the Article's application to the share of capital attributable to the Swedish partner of the SAS consortium.
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