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<h1>Comprehensive Tax Framework Governs Capital Taxation Across Borders to Prevent Double Taxation and Ensure Fair International Fiscal Treatment</h1> The statutory provisions outline taxation rules for capital across contracting states. Immovable property can be taxed in the state where located. Movable business property of a permanent establishment is taxable in the state where established. Capital from international shipping and aircraft operations is taxable only in the enterprise's home state. All other capital elements of a resident are taxable solely in their home state, preventing double taxation and establishing clear jurisdictional guidelines for capital taxation.