Article 23 - Property (Capital) - Belarus

ARTICLE 23 PROPERTY (CAPITAL) 1. Property (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. Property (Capital) represented by property other than immovable 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 property other than immovable 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. Property (Capital) represented by ships and aircraft operated in international traffic or by boats engaged in inland waterways transport and by property other than immovable property pertaining to the operation of such ships, boats and aircraft shall be taxable only in the Contracting State of which the owner of such ships, boats, aircraft or property is a resident. 4. All other elements of property (capital) of a resident of a Contracting State shall be taxed only in that State.