Capital gains taxation: immovable property and permanent establishment assets taxable where situated, with specific share disposal rules. Article 13 allocates taxation of capital gains: immovable property gains are taxable where the property is situated; gains of movable property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is located; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence; specific rules govern taxation of shares depending on acquisition date, with a transitional tax-rate limitation for an interim period; all other gains are taxable only in the alienator's State of residence.