Capital gains allocation: property character and residence determine which State may tax the gain on alienation.

Capital gains on alienation are allocated by property type and residence: immovable property situated in a Contracting State may be taxed in that State; movable property forming part of a permanent establishment or fixed base in the other State may be taxed in that State; ships and aircraft in international traffic are taxable only in the alienator's State of residence; shares principally representing immovable property may be taxed where the immovable property is situated; other shares may be taxed in the company's State of residence; all other property gains are taxable only in the alienator's State of residence.

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