Common use of Capital Clause in Contracts

Capital. 1. Capital represented by immovable property 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 movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is resident. 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 property, 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 movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated. 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, 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 movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated. 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 property, 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, 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, traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is residentthat State. (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, traffic and by movable property pertaining to the operation of such ships or aircraftships, shall be taxable only in the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated. 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 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, 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, traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is residentthat State. (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 property, 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, 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 or aircraftand aircraft and boats, shall be taxable only in the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated. (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 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 that 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 by an enterprise of Contracting State in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is residentthat State. 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, 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 Statethe Contracting State in which the permanent establishment or fixed base is situated. 3. Capital 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 the Contracting State of in which the place of effective management (i.e. head office) of the enterprise operating such ships or aircraft is residentsituated. 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 property, 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 a resident 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 aircraft transport vehicles operated by a resident of a Contracting State in international traffic, traffic and by movable property pertaining to the operation of such ships or aircrafttransport vehicles, shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is residentthat State. 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 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, 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 movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State of in which the enterprise operating such ships or aircraft is a resident. 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 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, 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 and aircraft operated in international traffictraffic by an enterprise resident in a Contracting State, and by movable property pertaining to the operation of such ships or aircraftmeans of transport, shall be taxable only in the that Contracting State of which the enterprise operating such ships or aircraft is residentState. 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 one of the States 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 one of the States has in the other Contracting State, State or by movable property pertaining to a fixed base available to a resident of a Contracting State one of the States 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, traffic and by movable property pertaining to the operation of such ships or aircraft, shall be aircraft are taxable only in the Contracting State of in which the enterprise operating profits from the operation of such ships or aircraft is residentare taxable according to the provisions of the Agreement mentioned in Article 8 of this Convention. 4. All other elements of capital of a resident of a Contracting State one of the States shall be taxable only in that State.

Capital. 1. Capital represented by immovable property 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, 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, traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is residentthat State. 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 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. 2.- Capital represented by movable property forming part of the business property of a permanent establishment which of an enterprise of a Contracting State has in the other Contracting Stateenterprise, 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 Statethe Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships ships, aircraft and aircraft road transport vehicles operated in international traffic, transport and by movable property pertaining to the operation of such ships or aircraftships, aircraft and road transport vehicles shall be taxable only in the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated. 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 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, 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, aircraft and aircraft containers operated in international traffic, traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships or ships, aircraft, and containers shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is residentthat State. 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 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 that 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 by an enterprise of a Contracting State in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is residentthat State. 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 property, 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, 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 movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated. (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 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, aircraft, railway and aircraft road vehicles 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 the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated. 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 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, 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 movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State of which the enterprise operating such ships or aircraft is resident. 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 one of the States 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 one of the States has in the other Contracting State, State or by movable property pertaining to a fixed base available to a resident of a Contracting State one of the States 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, traffic and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in the Contracting State of in which the place of effective management of the enterprise operating such ships or aircraft is residentsituated, due regard being had to the provisions of paragraph 2 of Article 8. 4. All other elements of capital of a resident of a Contracting State one of the States shall be taxable only in that State.. Chapter V.