МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 22
                               Capital

     1.  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.  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  ships  and  aircrafts  operated  in
international  traffic  and  by  movable  property  pertaining  to the
operation  of  such  ships and aircrafts, shall be taxable only in the
Contracting  State  of which the owner of such ships and aircraft is a
resident.
     4.  All  other elements of capital of a resident of a Contracting
State shall be taxable only in that State.