Capital gains taxation: source State may tax gains from alienation of immovable property and certain substantial shareholdings.

Article 13 grants the source State taxing rights over gains from immovable property situated there; gains from movable property forming part of a permanent establishment or a fixed base may likewise be taxed where that establishment or base is located. Ships and aircraft in international traffic are taxed only at the place of effective management. Shares principally deriving value from immovable property of the other State and constituting a substantial interest may be taxed by that State. Other gains are taxable only in the alienator's State of residence, with a specific rule allowing taxation of certain ten percent share disposals by the State of the company and exceptions for reorganisations and short term former residents.

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