ARTICLE 21
Capital
(1) Capital comprised of immovable property as defined in Article 6 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be liable to taxation in that other State.
(2) Capital represented by movable property forming a part of the business property of a permanent establishment, which an enterprise of a Contracting State has in the other Contracting State, may be liable to taxation in that other State.
(3) Capital represented by ships or aircraft operated in international traffic, by boats employed for inland navigation, and by movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
(4) Capital comprised of shares, holdings, or other similar corporate rights, or those owned by any other type of body corporate, or by similar rights, whose worth is more than 50 percent, derived directly or indirectly, from immovable property situated in a Contracting State, or by shares, holdings, or other rights, which grant the owner of the same the right of enjoyment of immovable property situated in a Contracting State, may be liable to taxation in the State wherein the immovable property is situated.
(5) All other capital assets pertaining to a resident of a Contracting State shall only be liable to taxation in that State.