Capital gains taxation: immovable-property-linked gains taxable in the State where the property is situated.

Capital gains allocation depends on asset connection: gains from immovable property are taxable where located; gains from movable property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is situated; disposals of ships or aircraft in international traffic are taxable only in the alienator's State of residence. Share disposals deriving substantial value from immovable property may be taxed in the State where the property is situated, while other share disposals may be taxed in the company's State of residence; other property gains remain taxable only in the alienator's residence State.

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