Capital gains allocation: source state may tax immovable property, PE-related assets and resident company shares; other gains taxed in residence.

Article 13 allocates taxation of capital gains: immovable property situated in the other Contracting State, movable property forming part of a permanent establishment or a fixed base used for independent personal services, and gains from alienation of resident company shares may be taxed in the State where the property or enterprise interest is situated; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; all other gains are taxable only in the alienator's State of residence.

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