Article 23 - Capital - Finland (Old - Effective upto 31-3-2011)

ARTICLE 23 - Capital - 1. Capital represented by immovable 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 that other State. 2. Capital represented by shares or other corporate rights referred to in paragraph (4) of article 6 and owned by a resident of a contracting State may be taxed in the contracting State in which the movable property held by the company is situated. 3. 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. 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 place of effective management of the enterprise is situated. (5) Elements of capital of a resident of a contracting State not dealt with in the foregoing paragraphs of this article shall be taxable only in that State except that, if such elements are situated in the other contracting State they may also be taxed in accordance with the law of that other State.