Capital gains taxation: immovable property and PE-linked disposals may be taxed where the property or PE is located.

Capital gains from alienation are apportioned by property type and nexus: immovable property and disposals tied to a permanent establishment or fixed base in the other State may be taxed in that State; ships and aircraft used in international traffic are taxable only in the enterprise's residence State; gains from shares principally representing immovable property may be taxed where the immovable property is situated, whereas other share disposals and other unspecified property gains are taxable in the alienator's State of residence.

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