Capital gains allocation: treaty links taxing rights to property situs, permanent establishment, management place, or residence. The DTAA allocates taxation of capital gains by property category: gains from immovable property are taxable in the State where the property is situated; gains from business property of a permanent establishment, including its disposal, are taxable in the State of the permanent establishment; gains from ships or aircraft in international traffic and related movable property are taxable in the State of the enterprise's place of effective management; gains from disposal of shares representing chiefly immovable property are taxable in the State where the property is located; other share disposals may be taxed in the company's State of residence; all other gains are taxable only in the alienator's State of residence.