Capital gains taxing rights allocate jurisdiction by property type and taxpayer residence under the DTAA.

Gains from alienation of immovable property are taxable in the State where the property is situated. Gains from movable property forming part of the business property 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 State of the alienator's residence. Gains on shares linked principally to immovable property may be taxed where that property is located; other share gains may be taxed in the company's State of residence. All other property gains are taxable only in the alienator's State of residence.

---

---

---