background image
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 22

Capital

(1) Capital represented by immovable property, which is owned by a person with permanent residency in a Contracting State and situated in the other Contracting State, may be taxed in that other State.

(2) Capital which is represented by movable property forming part of the commercial property of a permanent establishment which a person with permanent residency in a Contracting State has in the other Contracting State, or which is represented by movable property pertaining to a fixed base available to a person with permanent residency in a Contracting State in the other Contracting State for purposes of conducting independent personal activity, may be taxed in that other State.

(3) Capital which is represented by conveyances used by a person with permanent residency in a Contracting State for international traffic, and movable property pertaining to the operation of such conveyances, shall be taxable only in that State.

(4) All other kinds of capital of a person with permanent residency in a Contracting State shall be taxable only in that State.