Capital gains taxation under DTAA: taxing rights allocated by asset type, location, and residence of the alienator.

The treaty allocates taxing rights over capital gains by asset type and location: immovable property situated in a Contracting State may be taxed in that State; gains from movable property of a permanent establishment or fixed base may be taxed where that establishment or base is located, including on sale of the establishment or base; ships and aircraft in international traffic are taxable only in the alienator's State of residence; shares deriving principally from immovable property may be taxed in the State where the immovable is situated; other shares may be taxed in the company's residence State; all other gains are taxable only in the alienator's State of residence.

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