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          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.

          <h1>Capital gains sourcing rules: allocation of taxing rights for immovable property, PE/fixed base assets, and international-traffic exclusions.</h1> Article 13 grants taxing rights over capital gains: immovable property gains are taxable where the property is located; gains from movable property forming part of a permanent establishment or pertaining to a fixed base used for independent services may be taxed in the State where that PE or fixed base exists; gains from ships or aircraft operated in international traffic and their operational movable property are taxable only in the enterprise's State of residence; all other capital gains are taxable only in the alienator's State of residence.

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