Capital gains: allocation rules permit taxation by source state for disposals of immovable and certain enterprise-linked property.

Capital gains are allocated by reference to the nature and source of the property: gains from immovable property may be taxed where the property is located; gains from movable property of a permanent establishment or fixed base may be taxed where that establishment or base is situated, including on disposal of the establishment or base; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; gains from shares tied principally to immovable property may be taxed where that immovable property is located, while other share disposals may be taxed in the company's State of residence; remaining gains are taxable only in the alienator's State of residence.

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