ARTICLE 22
Capital
(1) Immoveable property that belong to a person resident in one Contracting State and are located in the other Contracting State can be taxed in the other State.
(2) Moveable assets that are the business assets of a permanent establishment that a business of one Contracting State maintains in the other Contracting State, or that belong to a fixed establishment which is at the disposal of a person resident in one Contracting State for the purpose of performing freelance work in the other Contracting State, can be taxed in the other State.
(3) Sea vessels and aircraft that are operated in international traffic as well as moveable assets that serve the operation of the vessels or aircraft can only be taxed in the Contracting State in which the business's place of effective management is located.
(4) All other assets belonging to a person resident in one Contracting State can only be taxed in this State.