Capital gains rules allocate taxing rights between residence and source for different asset categories under the tax treaty.

Allocation of capital gains taxation differentiates asset categories: immovable property situated in a State may be taxed there; gains from business property of a permanent establishment or movable property tied to a fixed base may be taxed in the State of the establishment or fixed base; aircraft operated in international traffic and related movable property are taxable only in the enterprise's State of residence; disposals of shares deriving principally from immovable property may be taxed in the State where the immovable property is situated; other gains are taxable only in the alienator's State of residence.

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