ARTICLE 21
Capital
(1) The capital represented by immovable property situated in the other Contracting State may be taxed in that other State.
(2) Capital, represented by movable property, which forms 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 taxed in that other State.
(3) Ocean going ships and aircraft that are operated in international transport as well as movable property pertaining to the operation of these ships and aircraft may be taxed only in that Contracting State in which the place of effective management of the enterprise is located.
(4) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.