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 resi-

dent 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 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 enter-

prise is situated.

4. All other elements of capital of a resident of a Contracting State shall be taxable

only in that State.

CHAPTER IV

METHODS FOR ELIMINATION OF DOUBLE TAXATION

ARTICLE 23

ELIMINATION OF DOUBLE TAXATION

1. In the case of Portugal, double taxation shall be eliminated as follows:

a) Where a resident of Portugal derives income which, in accordance with the

provisions of this Convention, may be taxed in Georgia, Portugal shall al-

low as a deduction from the tax on the income of that resident an amount

equal to the income tax paid in Georgia. Such deduction shall not, how-

ever, exceed that part of the income tax as computed before the deduction

is given, which is attributable to the income which may be taxed in Geor-

gia;

b) Where in accordance with any provisions of this Convention income de-

rived by a resident of Portugal is exempt from tax in Portugal, Portugal

may nevertheless, in calculating the amount of tax on the remaining in-

come of such resident, take into account the exempted income.

2. In the case of Georgia, double taxation shall be eliminated as follows:

a) Where a resident of Georgia derives income or owns capital which, in ac-

cordance with the provisions of this Convention, may be taxed in Portugal,

Georgia shall allow:

(i) as a deduction from the tax on the income of that resident, an amount equal to the income tax paid in Portugal;

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