- 1
- Property represented by immovable property referred to in Article 6 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
- 2
- Property represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
- 3
- Property represented by ships, boats and aircraft operated in international traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships, boats and aircraft, shall be taxable only in that State.
- 4
- All other elements of property of a resident of a Contracting State shall be taxable only in that State.
