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 Contracting 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of effective management or head office of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to 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 the Contracting StateState in which such property is situated. (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 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 services, may be taxed in that other the Contracting StateState in which the permanent establishment or fixed base is situated. (3) . Capital represented by ships and aircraft owned operated by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or aircraft, and 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to 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 the Contracting StateState in which such property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented . Ships or aircraft operated in international traffic by ships and aircraft owned by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or aircraft, and 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 Contracting 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 Contracting 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 servicesState, may be taxed in that other Contracting State. (3) . Capital represented by property forming part of the business property of an enterprise and consisting of ships and or aircraft owned operated by a resident of a Contracting State and operated such enterprise in international traffic, and by traffic or of movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 pertain- ing 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, ser- vices may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that Contracting State. (4) All other elements of capital of a resident of a the Contracting State shall be taxable only in that Contracting Statewhich the place of effective man- agement of the enterprise is situated.

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 Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 servicesState, may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned ships, aircraft, railway or road vehicles operated in international traffic by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships ships, aircraft, railway or aircraftroad vehicles, 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of an enterprise of a Contracting State and operated that operates ships or aircraft in international traffictraffic represented by such ships or aircraft, 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 Contracting 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 shall be taxed taxable only in that other Contracting 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital of an enterprise of a Contracting State represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in paragraph 2 of Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, 6 may be taxed in that other the Contracting StateState in which such property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by ships . Ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and ships, aircraft, rail or road vehicles operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships ships, aircraft, rail or aircraftroad vehicles and boats, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital of an enterprise of a Contracting State represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, 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 Contracting 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 Contracting State.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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic 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 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to 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 the Contracting StateState in which such property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by ships . Ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and 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 that the Contracting StateState 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of an enterprise of a Contracting State and operated that operates ships or aircraft in international traffictraffic represented by such ships or aircraft, 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 Contracting 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 Contracting 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and 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 that the Contracting StateState 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 Contracting 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 shall be taxed taxable only in that other Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in paragraph 2 of Article 6, owned by a resident of a Contracting State and situated in the other Contracting StateVI, may be taxed in that other the Contracting StateState in which such property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by ships . Ships and aircraft owned operated in international traffic by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or aircraft, and 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in paragraph 2 of Article 6, owned by a resident of a Contracting State and situated in the other Contracting State, State may be taxed in that other Contracting 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 Contracting State. (3) . Capital represented by ships ships, aircraft, railway and aircraft owned road vehicles operated by a resident an enterprise of a Contracting State and 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 that the Contracting StateState in which the registered office of the enterprise is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) Capital represented by immovable property referred to in Article 66 of this Agreement, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the profits are taxable in accordance with Article 8 of this Agreement. (4) All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to 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 the Contracting StateState in which such property is situated. (2) Capital . Subject to the provisions of paragraph 3, 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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by ships . Ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to 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 the Contracting StateState in which such property is situated. (2) Capital . Subject to the provisions of paragraph 1, capital represented by movable property forming part of the business property of a permanent establishment or a fixed base of an enterprise may be taxed in the Contracting State in which the permanent establishment or the fixed base is situated. 3. Capital represented by ships and aircraft operated by 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable assets other than immovable property pertaining to the operation of such ships or aircraft, and 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 Contracting State.

Capital. (1) Capital represented by immovable property referred to 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 the Contracting StateState in which such property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by Notwithstanding the provisions of paragraph (2) of this Article, ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic 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 operator is a resident. (4) All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting 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 Contracting 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 Contracting State. (3) . Capital of an enterprise of a Contracting State represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and 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 Contracting 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 Contracting State. (2) . Capital represented by movable property forming part of the business property of a permanent establishment 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in Article 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 the Contracting StateState in which such immovable property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by ships . Ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to 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 Contracting Statethe State in which such property is situated. (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 State enterprise, 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 Contracting Statethe State in which the permanent establishment or fixed base is situated. (3) Capital represented by . Notwithstanding the provisions of paragraph 2, ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that Contracting Statethe 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 one of the States shall be taxable only in that Contracting State.. CHAPTER V Elimination of double taxation

Capital. (1) . Capital represented by immovable property referred to 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 the Contracting StateState 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 the Contracting StateState where the fixed base is situated. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that the Contracting StateState which, by reason of Article 8, has the right to tax the profits arising from such operations. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting 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 Contracting 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 Contracting State.of (3) . Capital represented by ships and aircraft owned operated by a resident an enterprise of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article article 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by any movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState in which the place of head office (i.e. 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 Contracting State.

Capital. (1) Capital represented by immovable property referred to 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 the Contracting StateState in which such property is situated. (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 State enterprise, 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 services, may be taxed in that other the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by ships Ships and aircraft owned operated in international traffic by a resident an enterprise of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and 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 Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by ships ships, aircraft and aircraft owned by a resident of a Contracting State and road vehicles operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or ships, aircraft, road vehicles and boats, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in paragraph 2 of Article 6, owned by a resident of a Contracting State and situated in the other Contracting State7, may be taxed in that other Contracting Statethe State in which such property is situated. (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 State enterprise, 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 Contracting Statethe State in which the permanent establishment or fixed base is situated. (3) Capital represented by . Notwithstanding the provisions of paragraph 2, ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that Contracting Statethe 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 9 shall apply. (4) . All other elements of capital of a resident of a Contracting State one of the States shall be taxable only in that Contracting State.. Chapter V

Capital. (1) Capital represented by immovable property referred to in Article 6, owned by a resident of a 6 paragraph 2 shall be taxable only in the Contracting State and situated in the other Contracting State, may be taxed in that other Contracting Statewhich such property is situated. (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 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 services shall be taxed taxable only in that other the Contracting StateState in which such permanent establishment or fixed base is situated. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in Article article 6, owned by a resident of a Contracting State and situated in the other Contracting Stateparagraph 2, may be taxed in that other Contracting Statethe State in which such property is situated. (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 State enterprise, 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 Contracting Statethe State in which the permanent establishment is situated. (3) Capital . Notwithstanding the provisions of paragraph 2, capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that Contracting Statethe State in which the place of effective management of the enterprise is situated, in accordance with the provisions of article 8, paragraph 2. (4) . All other elements of capital of a resident of a Contracting State one of the States shall be taxable only in that Contracting State.. Chapter V

Capital. (1) . Capital represented by immovable property referred to mentioned in Article 6, owned by a resident of a one Contracting State and situated in the other Contracting State, may be taxed in that other Contracting State. (2) . Capital represented by movable property forming a part of the business operational property of a permanent establishment establishment, which an enterprise of a one 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 servicesState, may be taxed in that other Contracting Statestate. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and ships, boats, airplanes, railway or road vehicles operated in international traffictraffic by an enterprise, and by or movable property pertaining to the operation of such ships ships, boats, airplanes, railway or aircraftroad vehicles, shall be taxable is liable to tax only in that Contracting StateState in which the seat of the actual (main) headquarters is situated. (4) . All other elements of capital of a resident of a Contracting State shall be taxable are liable to tax only in that Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that Contracting Statethe 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to in as defined by Article 6, owned 6 that is held by a resident of a Contracting State and situated which is located in the other Contracting State, State may be taxed in that such other Contracting State. (2) . Capital represented by movable property forming part of the business property of a permanent establishment or movable property belonging to a fixed place of business 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 Contracting State. (3) . Capital represented consisting of ships or aircraft operated by ships and aircraft owned by a resident of a Contracting State and operated an enterprise in international traffic, and by traffic as well as movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that the Contracting StateState in which the enterprise resides. (4) . All other elements of capital of a resident of a Contracting State shall only be taxable only in that Contracting State.. Chapter V Methods for the 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 Contracting 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 Contracting State. (3) . Capital represented by ships ships, aircraft, railway and aircraft owned by a resident of a Contracting State and road vehicles operated in international traffic, traffic and by movable property pertaining to the operation of such ships or ships, aircraft, railway and road vehicles, shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 servicesState, may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships or aircraftships, aircraft and boats, shall be taxable only in that the Contracting StateState 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 State, shall be taxable only in that Contracting 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 Contracting 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 Contracting State. (3) . Capital represented by property forming part of the business property of an enterprise and consisting of ships and or aircraft owned operated by a resident of a Contracting State and operated such enterprise in international traffic, and by traffic or of movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that the Contracting StateState 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 Contracting 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 Contracting 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 Contracting State. (3) Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to in Article 66 of this Convention, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting 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 Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that the Contracting StateState 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 Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in paragraph 2 of Article 6, owned by a resident of a Contracting State and situated in the other Contracting State7, may be taxed in that other the Contracting StateState in which such property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by . Notwithstanding the provisions of paragraph 2 of this Article, ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic 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 operator is a resident. (4) . All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State.

Capital. (1) . Capital represented by immovable property referred to property, as defined in paragraph 2 of Article 6, owned by a resident of a Contracting State and situated in the other Contracting State5, may be taxed in that other the Contracting StateState in which such property is situated. (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 State enterprise, 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 the Contracting StateState in which the permanent establishment or fixed base is situated. (3) Capital represented by ships . Ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that the Contracting StateState 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 Contracting State.. CHAPTER V

Capital. (1) . Capital represented by immovable property referred to in Article Articles 6, owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other Contracting State. (2) . Capital represented by movable moveable 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 moveable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State state for the purpose of performing independent personal services, services may be taxed in that other Contracting State. (3) . Capital represented by ships and aircraft owned by a resident of a Contracting State and operated in international traffic, traffic and by movable moveable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that Contracting Statethe 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 Contracting State.