Capital taxation under DTAA allocates taxing rights for immovable property and PE linked movable assets between states.

Article 23 grants the State where immovable property is situated the right to tax capital represented by that property; grants the State hosting a permanent establishment or fixed base the right to tax capital represented by movable business property related to that establishment or base; and confines taxation of capital in ships engaged in international traffic and their related movable property to the State of the enterprise's place of effective management.

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