Common use of Capital Clause in Contracts

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, 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 independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal servicesother Contracting State, may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by property forming part of the business property of an enterprise and consisting of ships and or aircraft operated by an such enterprise of a Contracting State in international traffic, and traffic or of movable property pertaining to the operation of such ships and aircraft 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships and Ships or aircraft operated in international traffic by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal services, other Contracting State may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships and 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, 6 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such ships and 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to in paragraph 2 of Article 6, may be taxed owned by a resident of a Contracting State and situated in the other Contracting State State, shall be taxable only in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal services, other Contracting State may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships ships, aircraft and aircraft 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 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 independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State. 3. Capital of an enterprise of a Contracting State 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 and aircraft or aircraft, shall be taxable only in that Contracting State. 4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Capital. (1. ) Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. (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 independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State has in the other Contracting State may be taxed in that other State. (3) Capital represented by 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 road vehicles and aircraft 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 State.

Capital. (1. ) Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. (2. ) Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal services, other Contracting State may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. (3. ) Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships and 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 State.

Capital. (1. ) Capital represented by immovable property, as defined property referred to in paragraph 2 of Article 6, may be taxed owned by a resident of a Contracting State and situated in the other Contracting State State, shall be taxable only in which such property is situatedthat other State. (2. ) Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal services, other Contracting State may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. (3. ) Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships ships, aircraft and aircraft 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base used for the performance of independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated.available to a resident of 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and by movable property pertaining to the operation of such ships and aircraft aircraft, shall be taxable only in that Contracting State. 4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Capital. (1. ) Capital represented by immovable property, as defined in paragraph 2 (2) of Article 6, 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 a fixed base used for the performance of independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. (3. Capital represented by ships ) Ships and aircraft operated in international traffic by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such ships and aircraft aircraft, shall be taxable only in that Contracting State. (4. ) All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Capital. 1. Capital represented by immovable property, property as defined in paragraph 2 of Article 6, article 6 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 or a permanent establishment of an enterprise or by movable property pertaining to a fixed base used for the performance of independent personal services, services may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such ships and 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 items of capital of a resident of a Contracting State shall be taxable only in that State.

Capital. (1. ) Capital represented by immovable property, as defined in paragraph 2 (2) of Article 6, 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State 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 operated by an enterprise of a Contracting State in international traffic, traffic and movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 67, 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State 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 operated by an enterprise of a Contracting State in international traffic, traffic and movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined in article 6, paragraph 2 of Article 62, 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital Notwithstanding the provisions of paragraph 2, capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such ships and aircraft 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 State.. Chapter V

Capital. 1. Capital represented by immovable property, property as defined by Article 6 that is held by a resident of a Contracting State and which is located in paragraph 2 of Article 6, the other Contracting State may be taxed in the Contracting State in which such property is situatedother State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of an enterprise or by movable property pertaining belonging to a fixed base used for the performance place of independent personal services, may be taxed in the Contracting State in business which the permanent establishment or 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 may be taxed in that other Contracting State. 3. Capital consisting of ships or aircraft operated by an enterprise in international traffic, and traffic as well as movable property pertaining to the operation of such ships and or 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 State.. Chapter V Methods for the Elimination of Double Taxation

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, property may be taxed in the Contracting State in which such the immovable property is situated. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base used available to a resident of a Contracting State in the other Contracting State for the performance purpose of performing independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by ships Ships and aircraft operated by an enterprise a resident of a Contracting State in international traffic, traffic and movable property pertaining to the operation of such ships and aircraft aircraft, shall be taxable only in that Contracting State. 4. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article article 6, may be taxed in the Contracting State in which such immovable 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 for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal servicesother Contracting State, may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships ships, aircraft and aircraft 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6VI, 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated in international traffic by an enterprise of a Contracting State in international traffic, and movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of establishment, which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal services, other Contracting State may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffictraffic and by boats engaged in inland waterways transport, and by movable property pertaining to the operation of such ships ships, aircraft and aircraft 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 State.

Capital. 1. Capital represented by immovable property, as property defined in paragraph 2 of Article 6, 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 which an enterprise of a Contracting State has in the other Contracting State or by movable property pertaining to a fixed base used for the performance purpose of performing independent personal services, may be taxed in the Contracting State in which where the permanent establishment or fixed base is situated. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and by movable property pertaining to the operation of such ships and aircraft 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used for Contracting State has in the performance of independent personal services, other Contracting State may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by property forming part of the business property of an enterprise and consisting of ships and or aircraft operated by an such enterprise of a Contracting State in international traffic, and traffic or of movable property pertaining to the operation of such ships and 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 State.

Capital. 1. Capital represented by immovable property, as defined property referred to in paragraph 2 of Article 6, owned by a resident of a State and situated in the other State, may be taxed in the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise of a State has in the other State or by movable property pertaining to a fixed base used available to a resident of a State in the other State for the performance purpose of performing independent personal services, services may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and by movable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, may be taxed in the Contracting State 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 of an enterprise enterprise, or by movable property pertaining to a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and movable property pertaining to the operation of such ships and 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 State.

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

Capital. 1. Capital represented by immovable property, as defined property referred to 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 the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable property forming part of the business property of a permanent establishment of which an enterprise or by movable property pertaining to of a fixed base used Contracting State has in the other Contracting State for the performance purpose of performing independent personal services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, and by movable property pertaining to the operation of such ships and 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 6, may be taxed in the Contracting State 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 or by movable property pertaining to a fixed base used for the performance of independent personal services, 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 in international traffic, traffic and movable assets other than immovable property pertaining to the operation of such ships 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 State.

Capital. 1. Capital represented by immovable property, as defined in paragraph 2 of Article 65, 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 a fixed base used for the performance of independent personal professional services, may be taxed in the Contracting State in which the permanent establishment or fixed base is situated. 3. Capital represented by ships Ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and movable property pertaining to the operation of such ships 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 State.. CHAPTER V

Capital. 1. Capital represented by immovable propertyproperty referred to in Articles 6, as defined owned by a resident of a State and situated in paragraph 2 of Article 6the other State, may be taxed in the Contracting State in which such property is situatedthat other State. 2. Capital represented by movable moveable property forming part of the business property of a permanent establishment of which an enterprise of a State has in the other State or by movable moveable property pertaining to a fixed base used available to a resident of a State in the other state for the performance purpose of performing independent personal services, services may be taxed in the Contracting State in which the permanent establishment or fixed base is situatedthat other State. 3. Capital represented by ships and aircraft operated by an enterprise of a Contracting State in international traffic, traffic and movable by moveable property pertaining to the operation of such ships 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 State.