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(c) Claims (including bonds, promissory notes and bills of exchange) are considered situated in the State where the debtor is domiciled or, if the debtor is a body corporate, in the State where the same is established or operates.

(d) Shares or interests in bodies corporate are considered situated in the State in which the body corporate is established or operates.

(e) Vessels, aircraft and any shares therein are considered situated in the place of registration thereof.

(f) Assets invested in a commercial or industrial undertaking, or connected with the practice of a profession, and assigned to a permanent establishment situated in either of the Contracting States, including the goodwill attaching thereto, are chargeable with tax in that State.

The term "permanent establishment" means a permanent place of business where the business of the undertaking is conducted wholly or in part.

A "permanent establishment" may be any of the following:

(i) Headquarters;

(ii) A branch;

(iii) An office;

(iv) A factory;

(v) A workshop;

(vi) A mine, a quarry or any other place where natural resources are exploited;

(vii) A construction or assembly site existing for more than twelve months.

(g) Patents, trade marks and designs shall be considered situated in the place where they are registered.

(h) Copyrights, exclusive rights, rights in artistic and scientific works and rights and permits to use any material, or any artistic or scientific work, covered by a copyright or by a patent, trade mark or design are considered situated in the place where the rights deriving therefrom are exercised.

(i) Any assets other than the abovementioned shall be considered situated in the State in which the deceased was domiciled at the time of his death.

Article IV. For the purposes of this Convention, "domicile" means the place where the business and interests of the deceased were mainly located.

If it is doubtful in which of the two States the deceased had his domicile, within the meaning of the preceding paragraph, or if the deceased could be considered to have been domiciled in both States, the question shall be decided by special agreement between the competent authorities of the two States. For that purpose, it shall be taken into consideration with which of the two States the deceased, at the time of his death, had closer personal and economic ties. If the deceased had his domicile in neither of the two Contracting States, he shall be considered to have been domiciled in the State in which he resided. If he resided in both States, the question of his domicile shall be decided by special agreement between the competent authorities of the two States.

Vol. 1332, I-22352