Capital gains taxation allocates taxing rights by property type, with residence rules for other disposals. Article 14 allocates taxing rights over capital gains: immovable property situated in a Contracting State may be taxed there; gains from movable property forming part of a permanent establishment or a fixed base in the other State may be taxed in that State; ships or aircraft in international traffic are taxable only in the alienator's State of residence; disposals of shares linked principally to immovable property or to a minimum participation threshold may be taxed in the State where the company is resident; all other gains are taxable only in the alienator's State of residence.