Capital taxation: immovable property taxed where located; PE and fixed base assets taxed where situated; ships by management place.

Article 23 attributes taxing rights: immovable property capital may be taxed in the State where the property is situated; 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 where the establishment or base is located; capital represented by ships in international traffic and related movable property is taxable only in the State of the enterprise's place of effective management.

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