Taxation of alienation of property allows source state to tax transfers tied to immovable property and permanent establishments. Income or gains from alienation are taxed according to the property's character: immovable property may be taxed by the State where situated; movable property forming part of a permanent establishment or pertaining to a fixed base may be taxed by the State where that permanent establishment or fixed base exists; ships or aircraft operated in international traffic are taxable only in the enterprise's State of residence; shares principally representing immovable property may be taxed in the State where the immovable is situated; other shares and other property are generally taxable only in the alienator's State of residence.