Taxation of Capital. Article 22
Taxation of Capital. Article 23
Taxation of 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 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 that Contracting State.
4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
Taxation of Capital. Capital represented by immovable property as defined in article 6, paragraph 2, may be taxed in the State where such property is situated.
Taxation of Capital. Capital
1. Capital represented by immovable property, as defined in paragraph 2 of Article 5, may be taxed in the Contracting State in which such property is situated.
2. Capital represented by movable property forming part of the business property of a permanent establishment of an enterprise, or by movable property pertaining to a fixed base used for the performance of professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated.
3. Ships and aircraft operated in international traffic and movable property pertaining to the operation of such ships and aircraft 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.
Taxation of Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of 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 the Contracting State in which the permanent establishment or fixed base is situated.
3. Capital represented by ships, and aircraft operated by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such means of transport 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.
Taxation of Capital. 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 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 professional services, may be taxed in that other State.
3. Capital represented by ships and aircraft operated by a resident of a Contracting State in international traffic and by movable property pertaining to the operation of such ships and aircraft, shall be taxable only in that State.
4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
Taxation of Capital. 1. Capital consisting of immovable property as discussed in article 6, that a resident of one Contracting State possesses, and that is situated in the other Contracting State is taxable in this other State.
2. Capital consisting of movable property that makes up a part of the assets of a permanent establishment that an enterprise of one Contracting State has in the other Contracting State, or of movable property that belongs to a fixed base of which a resident of one Contracting State makes use in the other Contracting State for the exercise of a profession of one who is self-employed, is taxable in this other State.
3. Capital consisting of ships, aircraft, or rail or road vehicles operated in international traffic, of boats used for inland navigation, as well as of movable property set aside for the operation of these means of transport, is taxable only in the Contracting State where the place of effective management of the enterprise is located.
4. All other elements of the capital of a resident of a Contracting State are taxable only in this State.
Taxation of 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, boats, aircraft and road-transport vehicles operated by a resident of a Contracting State in international traffic and by movable property pertaining to the operation of such ships, boats, aircraft and road-transport vehicles shall be taxable only in that State.
4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
Taxation of Capital. 1. Capital represented by immovable property, as defined in Article 6, owned by a resident of a Contracting State may be taxed in the Contracting State in which such property is situated.
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, aircraft, road and railway vehicles operated in international traffic or by movable property pertaining to the operations of such means of transport shall be taxable only in the Contracting State where a possessor of this capital is a resident.
4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State in which the capital is located.
