ARTICLE 22
Taxation of Capital
(1) Capital represented by immovable property as defined in Article 6, paragraph (2), may be taxed in the Contracting State in which the said property is situated.
(2) Capital represented by movable property forming part of the business property of a permanent establishment of an enterprise or pertaining to a fixed base used for the performance of independent personal services may be taxed in the Contracting State in which the permanent establishment or fixed base is situated.
(3) Ships and aircraft operated in international traffic and movable property pertaining to the operation of such ships and aircraft shall be taxable only in the Contracting State in which 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.