Common use of Taxation of Capital Clause in Contracts

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. Capital‌ (1. ) Capital represented by immovable property, as defined in paragraph 2 (2) of Article 56, 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 traffic, and movable property pertaining to the operation of such ships and aircraft aircrafts, 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, as defined property referred to in Article 6 paragraph 2 of Article 5, may shall be taxed taxable only 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, enterprise or by movable property pertaining to a fixed base used available for the performance purpose of professional services, may performing independent personal services shall be taxed taxable only in the Contracting State in which the such permanent establishment or fixed base is situated. (3. Ships ) Capital represented by ships and aircraft operated in international traffic traffic, and by movable property pertaining to the operation of such ships and aircraft 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. Capital‌ 1. Capital represented by immovable property, as defined in paragraph 2 of Article 56, 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, enterprise or by movable property pertaining to forming part of a fixed base used for the performance purpose of professional services, performing independent personal services may be taxed in the Contracting State in which the permanent establishment or the fixed base is situated. 3. Ships and aircraft operated in international traffic and as well as 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.. Chapter V.