Capital gains taxation under DTAA: source state taxes immovable and PE-related gains; other gains taxable at residence. Under the DTAA, the source State may tax gains from alienation of immovable property situated in that State and gains from movable property forming part of a permanent establishment or pertaining to a fixed base in that State, including disposal of the permanent establishment or fixed base. Gains from ships or aircraft in international traffic are taxable only in the State of the enterprise's place of effective management. Disposal of shares in a resident company may be taxed by that State, while other capital gains are taxable only in the alienator's State of residence.