Capital taxation under the treaty: immovable property and PE-related movables taxable where situated, ships and aircraft taxable only in residence.

The treaty allocates taxing rights by asset category and location: immovable property may be taxed in the State where situated; movable property forming part of a permanent establishment or pertaining to a fixed base may be taxed in the State where that PE or fixed base exists; and ships and aircraft operated in international traffic, and their operational movables, are taxable only in the State of residence of the enterprise operating them.

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