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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.



(1) Capital represented by immovable property as defined in paragraph (2) of Article XIII of this Agreement may be taxed in the Contracting State in which such property is situated.

(2) Subject to the provisions of paragraph (1), capital represented by assets forming part of the business property employed in a permanent establishment of an enterprise of a Contracting State, or by assets pertaining to a fixed base used for the performance of professional 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 assets, other than immovable property, pertaining to the operation of such ships and aircraft, shall be taxable only in the Contracting State which according to Article V of this Agreement has the right to tax the profits derived from such ships or aircraft.

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