Capital gains taxation: immovable property, permanent establishments and share disposals may be taxed in the source state. Gains from alienation of immovable property situated in the other Contracting State may be taxed in that other State. Gains from alienation of movable property forming part of a permanent establishment or pertaining to a fixed base in the other State, including alienation of that permanent establishment or fixed base, may be taxed in that other State. Shares deriving over half their value from immovable property in the other State may be taxed there; shares of a company resident in a Contracting State may be taxed in that State. Ships and aircraft in international traffic are taxable only in the alienator's State of residence. Other gains are taxable under domestic law where they arise.