Capital taxation rules allocate taxing rights by asset location, covering immovable property, PE movables, and international ships.

Article 23 allocates taxing rights over capital by asset type and location: immovable property taxed where situated; movable property forming part of a permanent establishment's business property or pertaining to a fixed base for independent personal services taxed in the State where that establishment or base exists; ships and aircraft operated in international traffic and their operational movables taxable only in the State of the enterprise; all other capital elements taxable only in the resident's State.

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