Capital gains taxation allocates taxing rights between source and residence states under property, establishment, and share disposals.

Capital gains are allocated by reference to the property's character and location: immovable property situated in one Contracting State may be taxed there; gains from movable property forming part of a permanent establishment or related to a fixed base may be taxed in the State of that permanent establishment or fixed base; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; gains on shares deriving principally from immovable property may be taxed in the State where that immovable property is situated; other gains on shares may be taxed in the company's State of residence; remaining gains are taxable only in the alienator's State of residence.

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