Capital gains taxation: source state may tax gains from alienation of immovable property located within its territory.

Article 13 allocates taxing rights over capital gains: immovable property situated in a Contracting State may be taxed by that State; gains from movable property of a permanent establishment or fixed base may be taxed by the State where that establishment or base is located; gains on ships or aircraft in international traffic are taxable only in the alienator's residence; shares of companies whose property is principally immovable may be taxed by the State where the immovable property is situated; other gains arising in a State may be taxed by that State.

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