Capital Gains Taxation
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Capital Gains Taxation

A Comparative Analysis of Key Issues

Edited by Michael Littlewood and Craig Elliffe

Capital gains taxes pose a host of technical and political design problems and yet, while the literature on the theory of capital gains taxation is substantial, little has been published on how governments have addressed these dilemmas. Written by a team of distinguished international experts, Capital Gains Taxation addresses the gap in the literature; it explains how a number of countries tax capital gains and the successes and pitfalls of these methods.
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Chapter 3: International aspects of capital gains taxation

Craig Elliffe


This chapter examines two broad areas of capital gains tax (CGT) design in respect of the taxation of non-residents. The first area relates to the domestic design of the tax and focuses on whether a CGT should apply comprehensively to all assets held by non-residents, or alternatively, to some limited subset of those assets. Is there any justification for limiting the scope of CGT to only certain types of assets when such assets are held by non-residents as opposed to residents? The second area is how double tax agreements (DTAs) interact with, or change, domestic CGT taxing rights. This area is intricately connected with the first area because the role of a DTA is to limit the taxing rights of contracting states primarily to avoid or reduce double taxation. Keywords: capital gains tax; non-residents taxation; double tax agreements; international tax system design

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