ARTICLE 21
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 that other State.
(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, may be taxed in that other State.
(3) Capital represented by property forming part of the business property of an enterprise of a Contracting State and consisting of ships, aircraft or road vehicles operated by such enterprise in international traffic or of movable property pertaining to the operation of such ships, aircraft or road vehicles, shall be taxable only in that State.
(4) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.