Capital gains taxation: source State may tax immovable and PE-linked asset disposals; residence applies otherwise. Article 14 assigns taxing rights: gains from alienation of immovable property are taxable in the State where the property is situated; gains from movable property forming part of a permanent establishment or linked to a fixed base may be taxed in the State where that establishment or fixed base is located; gains from ships or aircraft in international traffic are taxable only in the State of the enterprise's place of effective management; disposals of shares principally consisting of immovable property are taxable in the State where that property is located; other gains are taxable only in the alienator's State of residence.