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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 by immovable property referred to in Article 6 of this Convention, 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, may be taxed in that other State.

(3) Capital represented by ships or aircraft operated by an enterprise of a Contracting State in international traffic, as well as movable property pertaining to the operation of such ships and aircraft, shall be taxable only in that Contracting State.

(4) Capital represented shares or other rights, which grant the owner of the same the right of enjoyment of immovable property situated in a Contracting State, may be liable to be taxed in the Contracting State wherein the immovable property is situated.

(5) All other capital assets pertaining to a resident of a Contracting State shall only be taxed in that State.