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 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 State. (3) Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the Contracting State 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 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 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 State. (3) . Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the Contracting State 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 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 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 State. (3) Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the Contracting State 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 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 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 State. (3) . Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the Contracting State 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 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 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 State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boatsships or aircraft, shall be taxable only in the Contracting State in which the place profits from the aforesaid ships or aircraft are taxable according to the provisions of effective management of the enterprise is situatedArticle 8. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that 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 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 State. (3) Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the Contracting State 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 State.. CHAPTER V

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 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 State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boatsships or aircraft, shall be taxable only in the Contracting State in which the place profits from the aforesaid ships or aircraft are taxable according to the provisions of effective management of the enterprise is situatedArticle 8. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that 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 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 State. (3) . Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boats, shall be taxable only in the Contracting State 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 State.. Chapter V

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 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 State. (3) . Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft ships and boatsaircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. For the purposes of this paragraph the provisions of paragraph 2 of Article 8 shall apply. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that State.. Chapter V.

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 StateState , may be taxed in that other 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 for the purpose of performing independent personal servicesservices , may be taxed in that other State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, ships or aircraft and boats, shall be taxable only in the Contracting State in which the place profits from the aforesaid ships or aircraft are taxable according to the provisions of effective management of the enterprise is situatedArticle 8. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that 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 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 State. (3) . Capital represented by ships ships, boats, aircraft and aircraft road transport vehicles operated in international traffic and by boats engaged in inland waterways transporttraffic, and by movable property pertaining to the operation of such ships, boats, aircraft and boatsroad transport vehicles, shall be taxable only in the Contracting State 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 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 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, may be taxed in that other State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transporttraffic, and by movable property pertaining to the operation of such ships, aircraft and boatsmeans of transport, shall be taxable only in the Contracting State in which the place of effective management profits of the enterprise is situatedare taxable according to Article 8 of this Convention. 4. Capital of an enterprise of a Contracting State represented by containers (4including trailers and related equipment for the transport of containers) used for the transport of goods or merchandise shall be taxable only in that Contracting State, except insofar as those containers or trailers and related equipment are used for transport solely between places within the other Contracting State. 5. All other elements of capital of a resident of a Contracting State shall be taxable only in that 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 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 State. (3) . Capital represented by ships ships, boats, aircraft and aircraft road-transport vehicles operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, boats, aircraft and boats, road-transport vehicles shall be taxable only in the Contracting State 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 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 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 State. (3) . Capital represented by ships ships, boats, aircraft and aircraft road-transport vehicles operated in international traffic and by boats engaged in inland waterways transporttraffic, and by movable property pertaining to the operation of such ships, boats, aircraft and boats, road-transport vehicles shall be taxable only in the Contracting State 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 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 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, services may be taxed in that other State. (3) . Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, ships and aircraft and boats, shall be taxable only in the Contracting State in which the place profits from the operation of effective management such ships or aircraft are taxable according to the provisions of the enterprise is situatedArticle 8 of this Convention. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that 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 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 State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boatsships or aircraft, shall be taxable only in the Contracting State in which the place profits from the aforesaid ships or aircraft are taxable according to the provisions of effective management Article 8 of the enterprise is situatedthis Convention. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that State. Chapter V Article 24 1. It is agreed that double taxation shall be avoided in accordance with the following paragraphs of this Article.

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 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 State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, ships or aircraft and boats, shall be taxable only in the Contracting State in which the place of effective management profits from the operation of the enterprise is situatedaforesaid ships or aircraft are taxable according to the provisions of Article 8 of the Convention. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that 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 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 State. (3) . Capital represented by ships and aircraft operated in international traffic and traffic, by boats engaged in used for inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and aircraft, or boats, shall be taxable only in the Contracting State 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 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 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 servicesprofessional service, may be taxed in that other State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, ships or aircraft and boats, shall be taxable only in the Contracting State in which the place profits from the aforesaid ships or aircraft are taxable according to the provisions of effective management Article 8 of the enterprise is situatedthis Convention. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that State.. CHAPTER V ELIMINATION OF DOUBLE TAXATION

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 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 State. (3) . Capital represented by ships and aircraft operated in international traffic and by boats engaged in inland waterways transport, and an enterprise of a Contracting State or by movable property pertaining to the operation of such ships, aircraft and boatsships or aircraft, shall be taxable only in the Contracting State in which the place of effective management profits from the operation of the enterprise is situatedship or aircraft are taxable according to the provisions of Article 8. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that 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 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, services may be taxed in that other State. (3) . Capital represented by ships and or aircraft operated in international traffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships, aircraft and boatsships or aircraft, shall be taxable only in the Contracting State in which the place profits from the aforesaid ships or aircraft are taxable according to the provisions of effective management Article 8 of the enterprise is situatedthis Convention. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that State.