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Untd A Emirates - Iraq Tax Treaty (2017, not yet in force) — Orbitax Tax Hub

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.

ARTICLE 23

Capital

(1) Capital represented in immovable property referred to in Article 7 herein, existing in a Contracting State and owned by a resident in the other Contracting State may be taxable only in the other Contracting State.

(2) Capital represented in movable property that are part of the property of activity exercised by a permanent establishment owned by a company of a Contracting State in the other Contracting State for the purposes of performing independent personal services, shall be taxable in the other Contracting State.

(3) Capital represented in ships and aircraft operating in international transport as well as capital represented in movable property in connection with the operation of such ships and aircraft shall be taxable only in the Contracting State where the actual headquarters of the enterprise management is situated.

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