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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 23

Capital

(1) Capital represented by immovable property referred to in Article 6 of the Convention, which is held by a resident of a Contracting State and which is situated in the other Contracting State shall be taxable in that other State;

(2) Capital represented by movable property which belongs to the assets of a permanent establishment which an enterprise of a Contracting State maintains in the other Contracting State, or movable property belonging to a fixed base which a resident of a Contracting State has available to him or her in the other Contracting State for the purpose of exercising independent professional services may be taxable in the Contracting State in which the permanent establishment or fixed base is situated.

(3) Capital represented by ships and aircraft operated by such enterprise in international traffic as well as by movable property used in the operation of these ships or aircraft shall only be taxable in the Contracting State where the place of effective management of the enterprise is located.

(4) All other items of capital of a resident of a Contracting State shall only be taxable in that State.