Taxation of capital: rules allocate source state taxing rights by asset type while reserving other capital to resident State. Article 24 allocates taxing rights over capital by asset class: immovable property is taxable in the State where located; movable property forming part of a permanent establishment or fixed base is taxable in the State of the establishment or base; ships, aircraft and their operating property are taxable only in the State of residence of the operating enterprise; shares linked to immovable property companies or substantial participations may be taxed in the relevant Contracting State; all other capital of a resident is taxable only in the resident State.