DT2520.22 - Argentina: double taxation agreement, Article 22: Capital

(1) Capital represented by immovable property referred to in Article 6 of this Convention, 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 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 movable property which an enterprise of a Contracting State has in the other Contracting State for the purpose of its business activities shall be taxable only in the first mentioned State where the business profits derived by that enterprise are taxable only in that first mentioned State in accordance with Article 7 of this Convention.

(4) 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 profits are taxable in accordance with Article 8 of the Convention.

(5) Other elements of capital of a resident of a Contracting State which are situated in the other Contracting State may be taxed in that State.

(6) All elements of capital of a resident of a Contracting State other than those referred to in paragraphs (1), (2), (3), (4) and (5) of this Article shall be taxable only in that State.