TAXATION OF CAPITAL. Article 22
TAXATION OF CAPITAL. Article 23
TAXATION OF CAPITAL. 1. Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
TAXATION OF CAPITAL. Capital Art. 22
TAXATION OF CAPITAL. Article 2316 § 1 Immovable property referred to in Article 6 paragraph 2 may be taxed in the Contracting State in which such property is situated. § 2 Movable property, is the business property of a permanent establishment of an enterprise or a part of the serving to the performance of professional fixed base, may be taxed in the Contracting State in which is situated the permanent establishment or fixed base. § 3 Ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships and aircraft, shall be taxable only in the Contracting State in which the place of effective management of the company. § 4 All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
TAXATION OF CAPITAL. Article 23 § 1 by immovable property referred to in Article 6 paragraph 2 may be taxed in the Contracting State in which such property is situated.
TAXATION OF CAPITAL. 4.16 While an appropriate balance must be struck in capital taxation between furthering economic goals and raising revenues, it is the objective to further increase the total contribution of capital taxes to overall revenues. The taxation of savings and capital will continue to be kept under review having regard to the Government’s objective of structuring the tax system so as to support employment, minimising financial imbalances and outflows, and ensuring equity as between the different forms of income.
TAXATION OF CAPITAL. [Compare: OECD Model | UN Model | Other Treaty/Model]
TAXATION OF CAPITAL. (1) Capital represented by immovable property referred to in Article 6 paragraph 2 shall be taxable only in the Contracting State in which such property is situated.
TAXATION OF CAPITAL. Art. 23.
