ARTICLE 22
Capital
(1) The capital represented by immovable property, such as defined in paragraph (2) of Article 6 shall be taxable in the Contracting State where such property is located.
(2) The capital represented by movable property forming part of a permanent establishment of an enterprise or by movable property capital represented by a fixed base for exercising an independent professional service shall be taxable in the Contracting State where the permanent establishment or fixed base is located.
(3) The ships and aircraft used in international traffic as well as the movable property affecting their use shall be taxable solely in that Contracting State where the place of effective management of the enterprise is located.
(4) Any other items of capital of a resident of a Contracting State shall be taxable solely in that State.