Capital gains allocation under tax treaty: source State may tax disposals of immovable property, PE assets, and certain shares.

Allocation of taxing rights distinguishes disposals by property type and taxpayer residence: immovable property situated in a Contracting State may be taxed there; movable property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is located (including sales of the establishment or base); ships and aircraft used in international traffic are taxable only in the alienator's State of residence; shares principally backed by immovable property may be taxed where the immovable property is situated; other resident-company shares may be taxed by the company's State; other gains follow domestic law.

---

---

---