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