ARTICLE 19
CAPITAL
(1) Capital represented by immovable property referred to in Article 3 owned by a resident of a Contracting State and situated in the other Contracting State may be taxed in that other state.
(2) Capital represented by shares or interests in a company or a body corporate whose assets consist mainly of immovable property situated in one of the Contracting States, or of rights relating to that property, may be taxed in the Contracting State in which the property is situated. For the purposes of this paragraph, property owned by that company or body corporate for its own industrial, commercial or agricultural use, or for the exercise of a non-commercial profession, shall not be included.
(3) 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 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.
(4) Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, 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.
(5) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
(6) Notwithstanding the provisions of the aforementioned paragraphs in this Article, with respect to the levying of the joint and several income tax on the capital of an individual residing in France who is a German citizen but not a citizen of France, the property owned by him outside France as of January 1 of each of the five calendar years following the year in which he becomes a resident of France is not included in the tax base for this five-year period.
If such individual loses his resident status in France for a period of no less than three years, then again becomes a resident of France, the property located outside France owned by it as of January 1 of each of the five calendar years following the year in which he once more becomes a resident of France is not included in the tax base for this five-year period.