Taxation of capital: treaty allocates taxing rights by asset type between source and resident states.

Allocation of taxing rights over capital depends on asset type and location: immovable property may be taxed in the State where situated; movable property of a permanent establishment or fixed base may be taxed in the State of that establishment or base; ships and aircraft in international traffic and their operating property are taxable only in the State of the enterprise; all other capital elements are taxable only in the State of residence.

---

---

---