Capital gains allocation: rules specifying which Contracting State may tax alienation proceeds of property and shares under DTAA

Gains from alienation of immovable property situated in a Contracting State are taxable in that State; gains from alienation of movable property forming part of a permanent establishment or pertaining to a fixed base may be taxed where that permanent establishment or fixed base is located; gains from ships or aircraft in international traffic are taxable only in the alienator's State of residence. Share disposals are allocated: shares deriving principally from immovable property may be taxed where that immovable property is situated, other resident-company shares may be taxed in the company's State of residence; all other gains are taxable only in the alienator's State of residence.

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