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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, owned by a resident of a Contracting State and situated in the other Contracting State may be taxed in the other Contracting State provided that the taxes are reduced by 50 per cent.

(2) Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, or represented by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in the other State in which the place of effective management of the fixed base or permanent establishment is situated, provided that the taxes shall be reduced by 50 per cent, and the public authorities are exempted from tax.

(3) Capital represented by ships and aircraft operated in the international traffic as well as capital represented by movable property dedicated for transport means shall be taxable only in the Contracting State in which the actual place of effective management of the enterprise is situated.