60 STAT.] UNITED KINGDOM-DOUBLE TAXATION-APR . 16 , 1945 (c) Debts, secured or unsecured, other than the forms of indebt- edness for which specific provision is made herein, shall be deemed to be situated at the place where the decedent was domiciled at the time of death; (d) Shares or stock in a corporation other than a municipal or governmental corporation (including shares or stock held by a nominee where the beneficial ownership is evidenced by scrip certificates or otherwise) shall be deemed to be situated at the place in or under the laws of which such corporation was created or organized; (e) Monies payable under a policy of assurance or insurance on the life of the decedent shall be deemed to be situated at the place where the decedent was domiciled at the time of death; (f) Ships and aircraft and shares thereof shall be deemed to be situated at the place of registration or documentation of the ship or aircraft; (g) Goodwill as a trade, business or professional asset shall be deemed to be situated at the place where the trade, business or profession to which it pertains is carried on; (h) Patents, trademarks and designs shall be deemed to be situated at the place where they are registered; (i) Copyright, franchises, and rights or licenses to use any copy- righted material, patent, trademark or design shall be deemed to be situated at the place where the rights arising therefrom are exercisable; (j) Rights or causes of action ex delicto surviving for the benefit of an estate of a decedent shall be deemed to be situated at the place where such rights or causes of action arose; (k) Judgment debts shall be deemed to be situated at the place where the judgment is recorded; Provided that if, apart from this paragraph, tax would be imposed by one Contracting Party on any property which is situated in its territory and passes under a disposition not governed by its law, this paragraph shall not apply to such property unless, by reason of its application or otherwise, tax is imposed or would but for some specific exemption be imposed thereon by the other Contracting Party. ARTICLE IV (1) In determining the amount on which tax is to be computed, Dedution permitted deductions shall be allowed in accordance with the law in force in the territory in which the tax is imposed. (2) Where tax is imposed by one Contracting Party on the death of a person who at the time of his death was not domiciled in any part of the territory of that Contracting Party but was domiciled in some part of the territory of the other Contracting Party, no account shall be taken in determining the amount or rate of such tax of prop- erty situated outside the former territory: Provided that this para- graph shall not apply as respects tax imposed- (a) in the United States in the case of a United States citizen dying domiciled in any part of Great Britain; or 1393
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