Capital gains taxation: residence and source rules permit taxing gains where immovable property or certain business assets are situated.

Capital gains taxation under the DTAA permits the source State to tax gains from alienation of immovable property situated in that State and gains on shares deriving more than 50% of their value from such immovable property; gains of movable property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is situated; gains from ships or aircraft in international traffic are taxable only in the enterprise's residence State; other share gains may be taxed in the company's residence State; remaining gains are taxable only in the alienator's residence State.

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