Capital gains jurisdiction: immovable and PE-linked property taxable where situated; other gains taxable in seller's residence.

Capital gains are allocated by property type and situs: gains from immovable property situated in the other Contracting State and gains from movable property forming part of a permanent establishment or pertaining to a fixed base in the other State may be taxed in that other State. Share disposals are taxable in the State where the company's immovable-property-based value is situated or in the company's State of residence for other shares. All other gains are taxable only in the alienator's State of residence.

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