Common use of ALIENATION OF PROPERTY Clause in Contracts

ALIENATION OF PROPERTY. 1. Income or gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6, and situated in the other Contracting State may be taxed in that other State. 2. Income or gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such income or gains from the alienation of such permanent establishment (alone or together with the whole enterprise) or such fixed base, may be taxed in that other State. 3. Income or gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 4. Income or gains from the alienation of any property, other than those mentioned in this Article, shall be taxable only in the Contracting State of which the alienator is a resident.

ALIENATION OF PROPERTY. 1. Income or gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6, 6 and situated in the other Contracting State may be taxed in that other State. 2. Income or gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such income or gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Income or gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic traffic, or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 4. Income or gains derived by a resident of a Contracting State from the alienation of shares or comparable interests in a company, the assets of which consist wholly or principally of real property situated in the other Contracting State, may be taxed in that other State. 5. Nothing in this Agreement affects the application of the laws of a Contracting State relating to the taxation of gains of a capital nature derived from the alienation of any property, property other than those mentioned in that to which any of the preceding paragraphs of this Article, shall be taxable only in the Contracting State of which the alienator is a residentArticle apply.

ALIENATION OF PROPERTY. 1. Income or gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6, 6 and situated in the other Contracting State may be taxed in that other State. 2. Income or gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such income or gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Income or gains derived by of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 4. Income or gains from the alienation of any property, property other than those mentioned that referred to in this Articleparagraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.