Capital gains taxation: taxing rights allocated by property type and residence, with special rules for shares and permanent establishments. Capital gains under the DTAA allocate taxing rights by property type: immovable property is taxable in the State where situated; movable property of a permanent establishment or fixed base may be taxed in the State of that permanent establishment or fixed base; ships and aircraft operated in international traffic are taxable only in the State of the enterprise; substantial-share disposals may be taxed in the State where the company is resident, while other share disposals and all other property gains are taxable only in the State of residence of the alienator.