Taxation of capital: immovable and PE-related movable property taxed where located; ships and other capital taxed by residence. Immovable property is taxable in the State where situated; movable property forming part of a permanent establishment or pertaining to a fixed base used for independent personal services may be taxed in the State where that establishment or base is located. Ships and aircraft operated in international traffic, and movable property used in their operation, are taxable only in the State of residence of the enterprise. All other elements of a resident's capital are taxable only in the State of residence.