Separate financial statements are used to determine the distribution of profit and over-indebtedness (art # ) and for assessing both income tax and capital tax
Some tax laws prescribe another base instead of cost, e.g., the value previously reported by the alienator of the asset for capital tax purposes.” [para.
In general, tax treaties apply to all income and capital taxes imposed by the contracting States, including taxes imposed by provincial (state), local and other subnational governments.
Remarks concerning capital tax As paragraph # is drafted, credit is to be allowed for income tax only against income tax and for capital tax only against capital tax
There are cases where because one State does not impose a capital tax or because both States impose capital taxes only on domestic assets, no double taxation of capital will arise.