Capital gains taxation: allocation of taxing rights between contracting states by property type and business presence.

The treaty allocates capital gains taxation by property category: disposals of immovable property are taxable where situated; gains from movable property of a permanent establishment or movable assets connected with a fixed base (including disposal of that establishment or base) may be taxed where the establishment or base is located; disposals of ships or aircraft in international traffic are taxable only in the alienator's State of residence. Share disposals principally deriving value from immovable property are taxable where the property is located; other share disposals may be taxed in the company's State of residence; remaining gains are taxable only in the alienator's residence.

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