ARTICLE 22
Capital
(1) Capital represented by immovable property referred to in Article 6 owned by a resident of a Contracting State and situated in the other Contracting State may be taxed in that other State.
(2) Capital represented by movable property forming part of the assets of a permanent establishment of an enterprise or movable property constituting a fixed base used for the exercise of an independent activity may be taxed in the Contracting State in which the permanent establishment or fixed base is located.
(3) Capital represented by ships and aircraft operated in international traffic and by 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 ship or aircraft of the enterprise is located.
(4) All other items of the property of a resident of a Contracting State shall be taxable only in that State.