Capital gains taxation allocates taxing rights between property location, permanent establishment, effective management, and taxpayer residence.

Capital gains taxation allocates taxing rights according to the property's connection with a Contracting State. Immovable-property gains may be taxed where the property is situated, while gains connected with a permanent establishment or fixed base may be taxed in the other State where that establishment or base exists. International ships, aircraft, and related movable property are taxable only where effective management is situated. Share gains may be taxed in the company's State of residence, while residual gains are taxable only in the alienator's State of residence.

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