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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, such as they are defined in paragraph (2) of Article 6, shall be taxable in the Contracting State where such immovable property is located.

(2) Capital represented by movable goods forming part of the business property of a permanent establishment of an enterprise or movable property which belong to a fixed base being used for the purpose of performing independent personal services, shall be taxable in the Contracting State where the permanent establishment or the fixed base is located.

(3) Ships and aircraft operated in international traffic and movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

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