Taxation of capital by asset type determines which state may tax based on situs and place of effective management.

Taxation of capital allocates taxing rights by asset type and situs: immovable property is taxable where situated; shares or corporate rights are taxable where the company's movable property is situated; movable property of a permanent establishment or fixed base used for independent services is taxable where that establishment or base is located. Ships and aircraft in international traffic, and related movable property, are taxable only in the Contracting State of the enterprise's place of effective management. Other capital elements are taxable in the resident State but may also be taxed by the other State if situated there under its law.

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