Taxation of capital: immovable and business-linked movable property taxed in source state; international transport assets taxed in resident state.

Capital taxation under the DTAA allocates taxing rights by asset character and location: capital represented by immovable property is taxable where situated; movable property forming part of a permanent establishment's business property or made available through a fixed base for independent personal services is taxable where that establishment or fixed base is located; ships, aircraft and motor vehicles operated in international traffic and related movable property are taxable only in the State of residence of the owning enterprise; all other capital is taxable only in the State of residence.

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