Capital gains taxation: source-state may tax gains on immovable property and certain resident-company share disposals.

Capital gains under the treaty allocate taxing rights by property category: immovable property situated in the other Contracting State may be taxed in that State; movable property forming part of a permanent establishment or fixed base, including disposals of such establishments or bases, may be taxed in the State where they are situated; ships and aircraft in international traffic are taxable only in the alienator's State of residence. Shares are treated by acquisition date, with pre cutoff acquisitions taxable only in the resident State and later acquisitions taxable potentially in the company's State of residence, subject to a transitional reduced-rate cap.

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