Taxation of capital: location and business connection determine whether capital is taxed in source or residence state. Immovable property situated in a Contracting State and owned by a resident of the other State is taxable in the State where the property is situated; movable property forming part of the 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 is located; ships and aircraft operated in international traffic and related movable property are taxable only in the State of enterprise operation; all other capital is taxable only in the State of residence.