Capital gains taxation under the treaty allocates taxing rights by asset type and business connection. Capital gains under the treaty allocate taxing rights by asset class. Gains from immovable property situated in the other Contracting State, and gains from movable property connected with a permanent establishment or fixed base in the other State, may be taxed in that State. Gains from ships or aircraft operated in international traffic are taxable only in the State of effective management. Gains from shares in a resident company may be taxed in that State, while other gains may be taxed in both Contracting States.