Capital gains taxation under the treaty allocates taxing rights by property type and situs for cross-border disposals.

Capital gains under the Korea DTAA allocate taxing rights by property type and situs: immovable property gains are taxable where situated; gains from movable property of a permanent establishment or fixed base, including disposal of that establishment or base, may be taxed where located; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; gains on shares of companies whose property principally comprises immovable property may be taxed where that immovable property is situated; other share disposals may be taxed in the company's residence where a significant shareholding threshold was met; all other gains are taxable only in the alienator's State of residence.

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