ARTICLE 23
U.S. Income Tax Treaty — Venezuela Income Tax Treaty - 1999 · 2026-10-03 edition · updated 2026-10-04 · United States
Capital
Capital represented by immovable property (real property) referred to in Article 6 (Income From Immovable Property (Real Property)), owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
Capital represented by personal (movable) property forming part of the business property of a permanent establishment that an enterprise of a Contracting State has in the other Contracting State, or by personal (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.
Capital represented by ships, aircraft, and containers owned by a resident of a Contracting State and used in international operations, and by personal (movable) property pertaining to the operation of such ships, aircraft, and containers shall be taxable only in that State.
All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
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