Capital taxation rules allocate taxing rights to the State where assets or business bases are located, with special airline consortium limits.

Article 23 allocates taxing rights over capital: immovable property capital is taxable in the State where situated; movable property within a permanent establishment or pertaining to a fixed base for independent services is taxable in the State of that establishment or fixed base; capital in ships and aircraft engaged in international traffic and related movable property is taxable only in the State of the enterprise operating them; a special proviso confines the Article's application to the share of capital attributable to the Swedish partner of the SAS consortium.

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