Capital gains taxation: immovable property and PE related gains taxable where situated; other gains taxed at residence.

Capital gains rules allocate taxation by property type and situs: gains from immovable property are taxable in the State where situated; gains from movable property of a permanent establishment or fixed base may be taxed where that PE or fixed base exists; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; gains from shares principally owning immovable property may be taxed in the State where the immovable property is situated; other share gains may be taxed in the company's State of residence; all other gains are taxable only in the alienator's State of residence.

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