Capital gains taxation: immovable property and shares linked to real property may be taxed where the property is located.

Capital gains are allocated by reference to property type and residence: immovable property situated in a Contracting State may be taxed there; gains from movable property of a permanent establishment or fixed base may be taxed where that establishment or base is situated; ships and aircraft in international traffic are taxable only in the alienator's State of residence. Shares and comparable interests that derive principally from immovable property may be taxed in the State where the property is located, while other gains not covered by these rules are taxable only in the alienator's State of residence.

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