ARTICLE 22
Property
(1) Property 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) Property 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 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 that other State.
(3) Property represented by ships, boats, aircraft, road and railway vehicles operated by an enterprise of a Contracting State in international traffic, and by movable property pertaining to the operation of such ships, boats, aircraft, road and railway vehicles shall be taxable only in that Contracting State.
(4) All other elements of property of a resident of a Contracting State shall be taxable only in that State.