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    <description>Taxation of capital is allocated by asset type and location: capital represented by immovable property or rights therein is taxable where situated; shares of companies whose assets are principally immovable are taxable where that property is located (excluding industrial or commercial property of the company); movable property of a permanent establishment or fixed base may be taxed where that establishment or base is located; ships and aircraft in international traffic are taxable only in the State of the enterprise&#039;s place of effective management; all other capital is taxable only in the State of residence.</description>
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      <description>Taxation of capital is allocated by asset type and location: capital represented by immovable property or rights therein is taxable where situated; shares of companies whose assets are principally immovable are taxable where that property is located (excluding industrial or commercial property of the company); movable property of a permanent establishment or fixed base may be taxed where that establishment or base is located; ships and aircraft in international traffic are taxable only in the State of the enterprise&#039;s place of effective management; all other capital is taxable only in the State of residence.</description>
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