Capital gains taxation: source state taxing rights for immovable property, PE assets, and certain shares; other gains taxable in residence. Article 13 provides that gains from alienation of immovable property situated in the other Contracting State and gains from movable property of a permanent establishment or fixed base in the other State may be taxed in that other State; disposals of ships or aircraft in international traffic are taxable only in the alienator's State of residence; disposals of shares deriving principally from immovable property may be taxed in the State where that property is situated; other gains are taxable only in the alienator's State of residence.