Capital gains allocation: source state taxes immovable property disposals and PE-related asset sales.

Gains from alienation of immovable property situated in the other Contracting State and gains from disposal of shares principally deriving value from such immovable property may be taxed in the source State. Gains from alienation of movable property forming part of the business property of a permanent establishment or of movable property pertaining to a fixed base in the other State may be taxed in that other State, while gains from international ships or aircraft are taxable only in the alienator's State of residence; other gains remain taxable only in the resident State.

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