Taxation of capital: source state may tax capital tied to immovable property or permanent establishments; other capital taxed by residence. Article 22 allocates taxing rights over capital: the source state may tax capital connected to territorial presence-immovable property situated there and movable property forming part of a permanent establishment or fixed base-while other elements of capital remain taxable only in the resident's state; ships and aircraft in international traffic and related movable property are taxable exclusively in the enterprise's residence under the OECD formulation, and the UN Model flags negotiable wording for bilateral agreement.