Capital gains taxation: location-based rules allocate taxable rights for property, PEs, ships and share disposals under DTAA.

Gains from alienation of immovable property are taxable in the State where the property is situated. Movable property forming part of a permanent establishment or pertaining to a fixed base may be taxed in the State of that establishment or base. Ships and aircraft operated in international traffic are taxable only in the enterprise's State of residence. Shares or comparable interests deriving more than 50% of their value from immovable property situated in the other State during the preceding 365 days may be taxed in that other State; other shares and partnership interests are taxable in the State of residence. Remaining property gains are taxable only in the alienator's State of residence if taxed there.

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