Taxation of gains on alienation may be allocated to source state depending on property type and nexus to permanent establishment. Income or gains from alienation of immovable property situated in the other Contracting State may be taxed in that State. Movable property forming part of a permanent establishment or pertaining to a fixed base in the other State, and gains from disposition of such establishment or fixed base, may be taxed in that State. Gains from international ships or aircraft disposals are taxable only in the enterprise's State of residence. Share disposals principally deriving value from immovable property may be taxed in the State where the immovable property is situated; other share disposals may be taxed in the company's State of residence. Other gains are taxable only in the alienator's residence State.