Common use of Capital Clause in Contracts

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 Contracting 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 base 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. (4) All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated in international traffic by a resident an enterprise of a Contracting State and operated in international trafficState, and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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, State may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management or head office of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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, State may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may also be taxed in that other Contracting State. (3) . Capital represented by ships ships, aircraft and aircraft owned by a resident of a Contracting State and containers operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraftships, aircraft and containers, shall be taxable only in that the Contracting StateState of which the enterprise owning such property is a resident. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 6article 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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting State. (2) . Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise a resident of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting State. (2) . Capital represented by movable property property, forming part of the business property of a permanent establishment establishment, which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base based available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and ships, aircraft owned by a resident of a Contracting State and or motor vehicle operated in international traffic, traffic and by movable property pertaining to the operation of such ships ships, aircraft or aircraftmotor vehicles, shall be taxable only in that the Contracting StateState of which the enterprise owning such property is a resident. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or ship and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 pertain- ing to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, ser- vices may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that Contracting State. (4) All other elements of capital of a resident of a the Contracting State shall be taxable only in that Contracting Statewhich the place of effective man- agement of the enterprise is situated.

Capital. (1) . Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated situated, in the other Contracting State, may be taxed in that other Contracting 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 state or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that the Contracting StateState in which the place of head office or of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated in international traffic carried on by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting State. (2) . Capital represented by movable property property, forming part of the business property of a permanent establishment establishment, which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and ships, aircraft owned by a resident of a Contracting State and or land vehicles operated in international traffic, traffic and by movable property pertaining to the operation of such ships ships, aircraft or aircraftland vehicles, shall be taxable only in that the Contracting StateState of which the enterprise owning such property is a resident. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated in international traffic by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 State, or by movable property pertaining to a fixed base available to which a resident of a Contracting State has in the other Contracting State for the purpose performance of performing independent personal independ- ent professional services, may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enter- prise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.. CHAPTER V ELIMINATION OF DOUBLE TAXATION

Capital. (1) . Capital represented by immovable property referred to in Article arti- cle 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 mov- able property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international trafficinterna- tional traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that Contracting State. (4) All other elements of capital of a resident of a the Contracting State shall be taxable only in that Contracting Statewhich the place of effective management of the enterprise is situated.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState in which the place of head office (effective management) of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated in international traffic and by a resident boats engaged in inland waterways transport by an enterprise of a Contracting State and operated in international trafficState, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Agreement, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated in international traffic by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) Capital represented by immovable property referred to in Article 66 of this Agreement, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the profits are taxable in accordance with Article 8 of this Agreement. (4) All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property 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 Contracting State. (2) . Capital represented by movable immovable 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 base available to a resident of a Contracting State in the other Contracting State used for the purpose performance of performing independent personal professional services, may be taxed in that other the Contracting StateState in which the permanent establishment or fixed base is situated. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State represented by ships and aircraft operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting State. (2) . Capital represented by movable property 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 the fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and ships, aircraft owned by a resident of a Contracting State and or motor vehicle operated in international traffic, traffic and by movable property pertaining to the operation of such ships ships, aircraft or aircraftmotor vehicles, shall be taxable only in that the Contracting StateState of which the enterprise owning such property is a resident. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base available to a resident of a Contracting State in the other Contracting State for the purpose of of. performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and or aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in paragraph 2 of Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, State may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships ships, boat, aircraft, railway and aircraft owned road vehicles operated by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or aircraft, means of transport shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships ships, boats and aircraft owned operated by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships ships, boats or aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of owned by a resident of a Contracting State and situated in the other Contracting State, shall be taxable only in that other Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated by a resident an enterprise of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to as defined in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships ships, aircraft and aircraft owned road vehicle operated by a resident enterprise of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships ships, aircraft or aircraft, road vehicle shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 69, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting State. (2) . Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise a resident of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base 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 Contracting State. (3) . Capital represented by ships ships, aircraft, boats, or other means of transport and aircraft owned by a resident of a Contracting State and containers operated in international traffic, and which is owned by movable property pertaining to the operation residents of such ships or aircrafta Contracting State, shall may be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall may be taxable taxed only in that Contracting State.

Capital. (1) . Capital represented by immovable property 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 Contracting 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 base available to a resident of a Contracting State in the other Contracting State used for the purpose performance of performing independent personal professional services, may be taxed in that other the Contracting StateState in which the permanent establishment or fixed base is situated. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State represented by ships and aircraft operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Agreement, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated in international traffic by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting State. (2) . Capital represented by movable property 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 the fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and ships, aircraft owned by a resident of a Contracting State and or motor vehicle operated in international traffic, traffic and by movable property pertaining to the operation of such ships ships, aircraft or aircraftmotor vehicle, shall be taxable only in that the Contracting StateState of which the enterprise owning such property is a resident. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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, State may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management or head office of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property property, referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting Contacting State, may be taxed in that other Contracting 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 base available to a resident of a Contracting State in the other Contracting State used for the purpose performance of performing independent personal professional services, may be taxed in that other the Contracting StateState in which the permanent establishment or fixed base is situated. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State represented by ships and aircraft operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and ships, boats or aircraft owned operated in international traffic by a resident of a Contracting State and operated in international traffic, and capital represented by movable property pertaining to the operation of such ships ships, boats or aircraft, aircraft shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and ships, aircraft owned by a resident of a Contracting State and or railway or road transport vehicles operated in international traffic, traffic and by movable property pertaining to the operation of such ships ships, aircraft or aircraftrailway or road transport vehicles, owned by an enterprise of a Contracting State, shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Agreement, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (§ 3) . Capital represented by ships ships, aircraft and aircraft owned by a resident of a Contracting State and road or railway vehicles operated in international traffic, and by movable property pertaining to the operation of such ships ships, aircraft or aircraftroad or railway vehicles, shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (§ 4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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 Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and ships, boats, aircraft, railway or road vehicles operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, means of transport shall be taxable only in that the Contracting StateState in which the place of effective management of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 base 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 Contracting State. (3) . Capital represented by ships and aircraft owned operated in international traffic by a resident an enterprise of a Contracting State and operated in international trafficState, and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that Contracting State. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

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, State may be taxed in that other Contracting 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 State, or by movable property pertaining to a fixed base adfixbease 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and internationafilctraanf d by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState of which the owner is a resident. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.