Capital gains allocation under DTAA: source-based taxation governs alienations of immovable property, business property, and shares.

Capital gains under the Kazakhstan DTAA allocate taxing rights by property type and situs: immovable property situated in a Contracting State is taxable there; gains from movable property constituting part of a permanent establishment or pertaining to a fixed base may be taxed in the State where that permanent establishment or fixed base is located, including gains on their alienation; gains from ships or aircraft in international traffic are taxable only in the resident State; disposals of shares are taxed according to whether the company's assets principally comprise immovable property, with other property taxable only in the alienator's State of residence.

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