Taxation of capital: capital in ships and aircraft used in international traffic is taxable only in the resident state. Capital represented by ships and aircraft operated in international traffic, and movable property pertaining to their operation, is taxable only in the state of residence of the operator; all other elements of a resident's capital may be taxed in both Contracting States.
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Provisions expressly mentioned in the judgment/order text.
Taxation of capital: capital in ships and aircraft used in international traffic is taxable only in the resident state.
Capital represented by ships and aircraft operated in international traffic, and movable property pertaining to their operation, is taxable only in the state of residence of the operator; all other elements of a resident's capital may be taxed in both Contracting States.
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