Capital taxation: source-state taxation allowed for immovable and business-linked movables, residence-state taxation for other capital.

Capital represented by immovable property situated in one Contracting State and owned by a resident of the other may be taxed in the State where the property is located; movable property forming part of business property of a permanent establishment or pertaining to a fixed base for independent personal services may be taxed in the State where that establishment or fixed base exists; capital in ships and aircraft in international traffic and related movable property is taxable only in the State of the enterprise; all other capital is taxable only in the State of residence.

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