Capital gains taxation: allocation between source and residence states based on asset type and permanent establishment nexus.

Allocation of taxation rights for capital gains depends on asset type and nexus: immovable property is taxable in the State where situated; gains from movable property of a permanent establishment or fixed base may be taxed where that establishment or base is located; ships and aircraft in international traffic are taxable only in the State of the enterprise's registered office; disposals of shares tied principally to immovable property are taxable in the State of that property, other share disposals in the company's residence State, and other gains in the alienator's residence except short-term gains sourced in the other State.

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