Capital taxation under the DTAA allocates tax by asset type and by connection to establishments or residence.

Capital taxation is allocated by asset type and use: immovable property situated in the other Contracting State may be taxed there; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State of that establishment or base; ships and aircraft operated in international traffic and their operational movable property are taxable only in the enterprise's State; all other elements of a resident's capital are taxable only in the State of residence.

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