Common use of CAPITAL GAINS Clause in Contracts

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. (1. ) 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. ) 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. (3. ) Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraftboats, shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated. (4. ) Gains from the alienation of any property property, other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffictraffic by an enterprise of a Contracting State, or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, of this Article shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. (1. ) 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 Contracting State. (2. ) 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, services including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other Contracting State. (3. ) Gains derived by a resident 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 Contracting State. (4. ) Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a recognised stock exchange, deriving more than 50% of their value directly or indirectly from immovable property situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, of this Article shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed basexxxxx, may xxx be taxed in that other otheer State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships or aircraft aorcraft operated in international traffic, traffic or movable mavable property pertaining to the operation of such ships or aircraftaircraaft, shall be taxable only in that State. 4. Gains from the alienation aalienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. (1. ) 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. ) 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, services including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. (3. ) Gains derived by a resident 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 Contracting State. (4. ) Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. (1. ) 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. ) 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. (3. ) Gains derived by a resident 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. ) Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident. However, the capital gains mentioned in the foregoing sentence and derived from the other Contracting State, shall be taxable in the other Contracting State if the time period does not exceed one year between acquisition and alienation.

CAPITAL GAINS. (1. ) 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. ) 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, services including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. (3. ) Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraftboats, shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated. (4. ) Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraftboats, shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of any property property, other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. (1. ) 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. ) 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, services including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. (3. ) Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. (4. ) Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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 contracting State may be taxed in that other State. 2. 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 Contrcating 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic, ternational traffic or movable mavable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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 the other Contracting State. 2. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that the other Contracting State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation alineation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation alineation 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 indenpendent personal servicesservice, including such gains from the alienation of such a permanent establishment (alone or with the whole whose enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships ship 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. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3the preceding paragraphs, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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 Contracting State. 2. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of an enterprise of a Contracting State from the alienation of ships ships, aircraft or aircraft road transport vehicles operated in international traffic, traffic or movable property pertaining to the operation of such ships ships, aircraft or aircraftroad transport vehicles, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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 contracting State may be taxed in that other State. 2. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships ships, aircraft or aircraft vehicles operated in international traffic, or movable property pertaining to the operation of such ships ships, aircraft or aircraftvehicles, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, traffic or of movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraftboats, shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone establishment(alone or with the whole enterprise) or enterprise)or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 1,2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic, traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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 Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 1,2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 of this Agreement and situated in the other Contracting State may be taxed in that other State. 2. 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, services including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, base may be taxed in that other State. 3. Gains derived by a resident 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. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 33 of this Article, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships vessels, vehicles or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships vessel or aircraftaircraft or vehicle, shall be taxable only in that State. 4. Gains from the alienation of any property property, other than that those referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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 Contracting State. 2. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that the other Contracting State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State.the Contracting State in which the place of effective management of the enterprise is situated.. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 33 of this Article, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships ship 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. Gains from the alienation of any property or assets other than that those referred to in paragraphs 1, 2 and 33 of this Article and paragraph 3 of Article 12, shall be taxable only in the Contracting Contacting State of which the alienator is a resident. Nothing in this paragraph shall prevent either Contracting State from taxing the gains or income from the sale or transfer of shares or other securities, provided that the transfer takes place in one of the Contracting States.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may shall be taxed taxable only in that other State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships ships, aircraft or aircraft road vehicles operated in international traffic, traffic or movable property pertaining to the operation of such ships ships, aircraft or aircraftroad vehicles, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 petaining to a fixed base available availabel to a resident of a Contracting State in the other Contracting State for fot the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such such, fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to mentioned in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than then that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such such, fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to mentioned in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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 taxes in that other State. 2. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed basebas, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in the Contracting State of which the enterprise is a resident. 4. Gains from the alienation of shares of a company whose property is constituted essentially by immovable property which is situated in a Contracting State may be taxed in that Contracting State. 45. Gains from the alienation of any property other than that referred to in the paragraphs 1, 2 2, 3 and 34, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to property, as defined in paragraph 2 of Article 6 and situated in the other Contracting State 6, may be taxed in that other Statethe Contracting State in which the immovable property is situated. 2. Gains from the alienation of movable property forming f orming 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 Co ntracting State for the purpose of performing independent personal professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base, may be taxed in that the other State. 3. Gains derived by a resident of a one of the Contracting State States from the alienation of ships or and aircraft operated in international traffic, or traffic and movable property pertaining to the operation of such ships or aircraft, and aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property or right other than that referred to those mentioned in paragraphs 1, 2 and 3, shall 3 may be taxable only taxed in the both Contracting State of which the alienator is a residentStates.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident an enterprise of a Contracting State from the alienation of ships ships, aircraft, road or aircraft railway transpor vehicles operated in international traffic, traffic or of movable property pertaining to the such operation of such ships or aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may shall be taxed taxable only in that other Statestate. 3. Gains derived by a resident 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, aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident 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. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, 3 of this Article shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 32. Gains derived by a resident 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, aircraft shall be taxable only in that State. 43. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident 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 StateContracting State in which the siege of the effective direction is situated. 4. Gains from the alienation of any property or assets,other than that those referred to in paragraphs 1, 2 and 33 , shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. Gains from form 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 servicesservice, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. .. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which where the alienator is a residentgains arise.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident 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 StateState of which the enterprise is a resident. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall 3 of this Article may be taxable only taxed in the Contracting State of in which the alienator is a residentincome arises.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraftboats, shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of aircraft or ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such aircraft or ships or aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, traffic by an enterprise of a Contracting State or of movable property pertaining to the operation of such ships or aircraft, the mentioned means of transport shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 1,2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident. Nothing in this paragraph shall prevent either Contracting State from taxing the gains or income from the sale or transfer of shares or other securities.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property property, other than that referred to in paragraphs 1, 2 2, and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident 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 StateContracting State of which the enterprise is a resident. 4. Gains from the alienation of any property or assets, other than that those referred to in paragraphs 1, 2 and 33 of this Article, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in the paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships, aircraft, railway or road vehicles operated in international traffic or movable property pertaining to the operation of such ships, aircraft, railway or road vehicles shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 4. Gains derived by a resident of a Contracting State from the alienation of ships shares deriving more than 50 per cent of their value directly or aircraft operated indirectly from immovable property situated in international traffic, or movable property pertaining to the operation of such ships or aircraft, shall other Contracting State may be taxable only taxed in that other State. 45. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 2, 3 and 3, 4 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships ships, boats, aircraft or aircraft road-transport vehicles operated in international traffic, traffic or movable property pertaining to the operation of such ships ships, boats, aircraft or aircraft, road-transport vehicles shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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 Contracting State. 2. 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 gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident 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, aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 1 and 32, shall be taxable only in the Contracting State of which the alienator is a resident.