Capital gains from immovable property may be taxed where the property is situated; other gains follow residence. Capital gains from alienation of immovable property situated in a Contracting State may be taxed in that State. Gains from movable property forming part of a permanent establishment or pertaining to a fixed base may be taxed where that establishment or base is located, including on alienation of the establishment or base. Ships and aircraft in international traffic are taxable only in the alienator's State of residence; shares or interests in entities whose property is principally immovable in a State may be taxed in that State. Other gains are taxable only in the alienator's residence State.