Capital taxation allocation: immovable and establishment-linked movable assets taxed where situated; residual capital taxed in resident state.

Article 24 distinguishes taxation of capital by location and use: immovable property is taxable in the State where situated; movable property forming part of a permanent establishment or fixed base is taxable in the State where that establishment or base is located; ships, aircraft in international traffic and associated movable property are taxable only in the State of residence of the enterprise; and all other capital elements of a resident are taxable only in the State of residence.

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