Taxation of capital: immovable property taxed in state where located; PE-related movable assets taxable in source state. Immovable property owned by a resident and situated in the other State may be taxed where located; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State of that permanent establishment or fixed base. Ships, aircraft and motor vehicles operated in international traffic and related movable property are taxable only in the State of residence of the enterprise; all other capital of a resident is taxable only in the 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.
Taxation of capital: immovable property taxed in state where located; PE-related movable assets taxable in source state.
Immovable property owned by a resident and situated in the other State may be taxed where located; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State of that permanent establishment or fixed base. Ships, aircraft and motor vehicles operated in international traffic and related movable property are taxable only in the State of residence of the enterprise; all other capital of a resident is taxable only in the State of residence.
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