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 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 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 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.

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 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 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.

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, may be taxed in that other State. 3. Capital represented by ships and aircraft aircraft, operated in international traffic and by 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.

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 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 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.

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 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 and aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise owning such ships or aircraft is situated. (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 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 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.

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 may be taxed in that other Contracting State. 3. Capital represented by ships and aircraft operated in international 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.

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 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 and or 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.

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 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 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 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.

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 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 and aircraft, aircraft shall be taxable only in the Contracting State in which the place of effective of 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.

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 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 and or 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.

Capital. 1. Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State Party and situated in the other Contracting StateParty, may be taxed in that other StateParty. 2. Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State Party has in the other Contracting State Party may be taxed in that other StateParty. 3. Capital represented by ships and or aircraft operated in international traffic traffic, and by movable property pertaining to the operation of such ships and or aircraft, shall be taxable only in the Contracting State Party 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 Party shall be taxable only in that StateParty.

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 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 and aircraft, shall be taxable only in the Contracting 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 shall be taxable only in that 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 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 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 and aircraft, shall be taxable only in the that Contracting State in which the place of effective management of the enterprise is situatedsituated . 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 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 and or 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.

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 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 enterprise, or by movable property pertaining to a fixed base used for the performance of a Contracting State has in the other Contracting State professional services, may be taxed in that other Statethe State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships 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. 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 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 State. Capital represented by shares or similar rights in a company the assets of which consist principally of immovable property situated in a Contracting State, shall be taxable in that 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 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.

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 may be taxed in that other Contracting State. 3. Capital represented by ships and aircraft operated in international 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.. 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 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 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 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 such as shares and securities of a resident of a Contracting State shall be taxable only in that State.

Capital. 1. Capital represented by immovable property referred to property, as defined in Article 6, owned by a resident paragraph 2 of a Contracting State and situated in the other Contracting Statearticle VI, 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 of an enterprise enterprise, or by movable property pertaining to a fixed base used for the performance of a Contracting State has in the other Contracting State 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 land vehicles operated in international traffic and by movable property pertaining to the their 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.

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 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 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.

Capital. 1. Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State Party and situated in the other Contracting StateParty, may shall be taxed taxable only in that other StateParty. 2. Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State Party has in the other Contracting State Party may be taxed in that other StateParty. 3. Capital represented by ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships and aircraft, aircraft shall be taxable only in the Contracting State Party 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 Party shall be taxable only in that StateParty.

Capital. 1. Capital represented by immovable unmovable property referred to 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 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 of an enterprise of a Contracting State has in the other Contracting State may be taxed in that other Statethe contracting State in which the permanent establishment is situated. 3. Capital represented by Notwithstanding the provisions of pagraph (2) of this Article, ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships and aircraft, shall be taxable taxble 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.

Capital. 1. Capital represented by immovable property referred to as defined in paragraph 2 of Article 6, owned by a resident 4 of a Contracting State and situated in the other Contracting State, this Convention may be taxed in that other 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 enterprise, or by movable property pertaining to a fixed base used for the performance of a Contracting State has in the other Contracting State professional services may be taxed in that other Statethe State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated in international 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. For the purposes of this paragraph the provisions of paragraph 2 of Article 7 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 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 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 and aircraft, shall be taxable only in the Contracting 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 shall be taxable only in that State.. Chapter V

Capital. 1. Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State Country and situated in the other Contracting StateCountry, may be taxed in that other StateCountry. 2. Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State Country has in the other Contracting State Country may be taxed in that other StateCountry. 3. Capital represented by ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships and aircraft, shall be taxable only in the Contracting State Country 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 Country shall be taxable only in that StateCountry.

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 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 of an enterprise or by movable property forming part of a Contracting State has in fixed base for the other Contracting State purpose of performing independent personal services may be taxed in that other Statethe Contracting State in which the permanent establishment or the fixed base is situated. 3. Capital represented by ships Ships and aircraft operated in international traffic and by an enterprise of a Contracting State, as well as movable property pertaining to the operation of such ships and aircraft, shall thereof may be taxable taxed only in the Contracting State in which the place of effective management of the enterprise is situated. 4. All other elements items of capital of a resident of a Contracting State shall be taxable only in that State.