Common use of Taxation of Capital Clause in Contracts

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. 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 servicesservice, may be taxed in that other State. 3. Capital represented by ships and or 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 the Contracting StateState in which the profits from the aforesaid ships or aircraft are taxable according to the provisions of Article 8, of this Convention. 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 referred to in Article 6, 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 International traffic by an enterprise of a Contracting State and by movable property pertaining to the operation of such ships or aircraft, and aircraft 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 State.

Taxation of Capital. 1. Capital represented by immovable property referred to property, 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 Statethe 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 enter prize 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, road and aircraft railway vehicles operated in international traffic by an enterprise of a Contracting State and or by movable property pertaining to the operation operations of such ships or aircraft, means of transport shall be taxable only in that 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 StateState in which the capital is located.