Taxation on capital: allocation of taxing rights for immovable property, business movable property, and international shipping. Taxation on capital allocates taxing rights by category: immovable property may be taxed where situated; movable property forming part of business property of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed where the establishment or fixed base is located; ships and aircraft engaged in international traffic and related movable property are taxable only in the State of the enterprise's place of effective management (subject to Article 8A(3)); other capital elements are taxable only in the State of residence.