background image
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 22

Capital

(1) Capital represented by immovable property owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in the other State in which the property is situated.

(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, shall be taxable in the other State.

(3) Capital represented by ships and aircraft operated in international traffic and boats used for internal navigation, as well as by movable property pertaining to the operation of such   ships, aircraft and boats, shall be taxable only in the Contracting State where the place of effective management of the enterprise is situated.

(4) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.