Capital gains taxation distinguishes property types, allocating source-state taxing rights for immovable, PE assets, certain shares, otherwise residence-state taxation.

Article 13 allocates taxing rights: gains from immovable property situated in the other Contracting State and gains from movable property forming part of a permanent establishment or fixed base in the other State may be taxed in that other State. Gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence. Gains from shares principally deriving value from immovable property situated in a State may be taxed in that State; other share gains of a resident company may be taxed in that State. All other gains are taxable only in the alienator's State of residence.

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