Article 22 - Capital

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..... acting State, may be taxed in that other State. [ Para 1 or Article 22 ] 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. [ Para 3 or Article 22 ] Capital of an enterprise of a Contracting State that operates ships .....

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..... l 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 i .....

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