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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 in immovable property referred to in Article 7 herein, existing in a Contracting State and owned by a resident in the other Contracting State may be taxable only in the other Contracting State.

(2) Capital represented in movable assets that are part of the assets of activity exercised by a permanent establishment owned by an enterprise of a Contracting State in the other Contracting State as well as capital represented in immovable property with respect to a fixed base available for a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services may be taxable in the other Contracting State.

(3) Capital represented in ships and aircraft operating in international transport as well as capital represented in movable assets in connection with the operation of such ships and aircrafts shall be taxable only in the Contracting State.

(4) All other items of capital situated in one of the Contracting State shall be taxable only in that State.