Capital gains taxation: rules assign taxing rights by asset type and situs for disposals under the tax treaty.

Capital gains taxation is allocated by asset type and situs: immovable property situated in a Contracting State may be taxed there; gains from movable business property forming part of a permanent establishment or fixed base may be taxed where that establishment or base is situated; ships, aircraft and land vehicles operated in international traffic (and related movable property) are taxable only in the State of registration and effective management; disposals of shares principally deriving value from immovable property may be taxed in the State where the immovable property is located; other share disposals may be taxed in the State of the company's residence; all other gains are taxable only in the alienator's State of residence.

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