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 business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed based available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
(3) Capital represented by ships, boats, aircraft, road and railway vehicles of an enterprise of a Contracting State, operated in international traffic and movable property pertaining to the operation of such ships, boats, aircraft and road and railway vehicles shall be taxable only in that State.
(4) Capital represented by shares or other corporate rights in a company the assets of which consist mainly of immovable property situated in a Contracting State may be taxed in that Contracting State.
(5) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.