- 1
- Capital represented by immovable property referred to in Article 6 of this Convention, owned by a resident of one of the States and situated in the other State may be taxed in that other State.
- 2
- Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of one of the States has in the other State or by movable property pertaining to a fixed base available to a resident of one of the States in the other State for the purpose of performing independent personal services may be taxed in that other State.
- 3
- Notwithstanding the provisions of paragraph 2 of this Article, ships and aircraft operated in international traffic and boats engaged in inland waterways transport, and movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the State in which the place of effective management of the enterprise is situated. For the purposes of this paragraph the provisions of paragraph 3 of Article 8 of this Convention shall apply.
- 4
- All other elements of capital of a resident of one of the States shall be taxable only in that State.
