ARTICLE 22
Capital
(1) Capital represented by immovable property referred to in Article 6, owned by a resident of the sovereign territory of a Contracting Party and situated in the sovereign territory of the other Contracting Party, may be taxed in the sovereign territory of that other Contracting Party.
(2) Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting Party has in the sovereign territory of the other Contracting Party or by movable property pertaining to a fixed base available to a resident of the sovereign territory of a Contracting Party in the sovereign territory of the other Contracting Party for the purpose of performing independent personal services, may be taxed in the sovereign territory of that other Contracting Party.
(3) Capital represented by ships and aircraft operated in international traffic, and by movable property pertaining to the operation of such ships and aircraft, shall be taxable only in the sovereign territory of the Contracting Party in which the place of effective management of the enterprise is situated.
(4) All other elements of capital of a resident of the sovereign territory of a Contracting Party shall be taxable only in the sovereign territory of that Contracting Party.