Capital gains taxation allocates source or residence taxing rights according to property type and presence of permanent establishments.

Capital gains taxing rights depend on property type and business attachment: immovable property and gains from movable property of a permanent establishment or fixed base may be taxed in the State where those assets or attachments are situated; gains from ships and aircraft in international traffic are taxable only in the alienator's State of residence; gains from shares chiefly representing immovable property may be taxed in the State where the immovable property is located; other shares may be taxed in the company's State of residence; all other gains are taxable only in the alienator's State of residence.

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