Capital gains taxation: source-state taxing rights for immovable property, permanent establishments, and qualifying share transfers. The treaty allocates taxing rights on capital gains by classifying property: gains from immovable property are taxable where situated; gains from movable property forming part of a permanent establishment or fixed base, including disposal of that establishment or base, are taxable where the establishment or base is located; gains from ships or aircraft in international traffic are taxable only in the enterprise's State of residence; gains from shares deriving most of their value from immovable property may be taxed in the State where that property is situated, while other share gains may be taxed in the company's State of residence; remaining gains are taxable only in the alienator's State of residence.