ARTICLE 22
Property
(1) Immovable property within the meaning of 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) 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 movable property pertaining to a fixed base available to a resident of a Contracting State for the purpose of performing independent personal services in the other State, may be taxed in that other State.
(3) Ships and aircraft operated in international traffic and ships providing domestic shipping and movable property serving the operation of those ships or aircraft may be taxed only in the Contracting State in which the place of effective management is located.
(4) All other elements of property of a resident of a Contracting State shall be taxable only in that State.