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Brief
This article discusses the taxation rules for income from immovable property, business profits, shipping and air transport, associated enterprises, dividends, interest, royalties, and technical assistance. The rules aim to prevent double taxation and ensure that businesses are taxed fairly in the countries where they operate.
Key points:
- Income from immovable property is taxable in the country where the property is located.
- Business profits are taxable only in the country of operation, but may be taxed in another country if a permanent establishment is present.
- Shipping and air transport income is taxable only in the country of operation, unless it's exclusive to one country.
- Associated enterprises can be taxed in either country if conditions differ from independent enterprises.
- Dividends are taxable in both countries, but with a maximum tax rate in the recipient country.
- Interest and royalties are generally not exempt from taxation and may be taxed in both countries.
These rules aim to promote fair competition among businesses across different countries and prevent double taxation.
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