Capital gains taxation: source State may tax disposals tied to immovable property, permanent establishments, or fixed bases. Capital gains under the Czech Republic DTAA allocate taxing rights by reference to the nature and location of the property: immovable property situated in the source State and gains from movable property of a permanent establishment or fixed base in the source State may be taxed there; enterprise gains from ships or aircraft in international traffic are taxable only in the enterprise's residence State; disposals of shares that principally represent immovable property may be taxed in the State where that property is situated; other capital gains are taxable only in the alienator's State of residence.