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 or of such a fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 such operation shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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, 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 other Contracting State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 operation ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains from the alienation of shares of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that Contracting State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this Article shall Article, arising in a Contracting State, may be taxable only taxed in the that Contracting State of which the alienator is a residentState.

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 of a Contracting State from the alienation of sharesships or aircraft, other than shares traded on a Stock Exchange recognised by operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the other operation of such ships, aircraft or boats, shall be taxable only in the Contracting State, deriving at least three quarters in which the place of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other Stateeffective management of the enterprise is situated. 4. Gains derived by a resident of a Contracting State from the alienation of ships shares or aircraft operated comparable interests in international traffic a company, the assets of which consist wholly or movable principally of immovable property pertaining to such operation shall be taxable only situated in the other Contracting State of which the alienator is a residentState, may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this Article 1 to 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 a fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on ships or aircraft operated in international traffic by an enterprise of a Stock Exchange recognised by the other Contracting State, deriving at least three quarters or movable property pertaining to the operation of their value directly such ships or indirectly from immovable property situated aircraft, shall be taxable only in that other Contracting State may be taxed in that other State. 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 the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property, other than that referred to such operation in paragraphs 1 to 4, shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 sharesships, other than shares traded on a Stock Exchange recognised by aircraft or containers (including trailers and related equipment for the transport of container) operated in international traffic shall be taxable only in that Contracting State. The provisions of this paragraph, however, shall not apply if the containers or trailers and related equipment are used for transport solely between places within the other Contracting State, deriving at least three quarters . 4. Gains from the alienation of their value shares of the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in that other a Contracting State may be taxed in that other State. 45. Gains derived by from the alienation of shares other than those mentioned in paragraph 4 representing a participation of at least 10 per cent in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of ships or aircraft operated any property other than that referred to in international traffic or movable property pertaining to such operation paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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, 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 other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffic and movable property, pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State in which the place of head office (i. e. effective management) of the enterprise is situated. 4. Gains from the alienation of shares of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that Contracting State. 5. Xxxxx from the alienation of shares other than those mentioned in paragraph 4 representing a participation of 25 per cent in a company which is a resident of a Contracting State may be taxed in that Contracting State. 6. Gains derived by a resident of a Contracting State from the alienation of shares, any property other than shares traded on a Stock Exchange recognised by that referred to in paragraphs 1 to 5 and arising in the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other Contracting State. 4. 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 such operation shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 state from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State state may be taxed in that other StateContracting 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 from the alienation of ships or aircraft operated in international traffic and movable property pertaining to the operation of such ships or aircraft which are received by a resident of a Contracting State shall be taxable only in that Contracting State. 4. Gains from the alienation of shares in the capital of a Company, the assets of which consist mainly, directly or indirectly, of immovable property situated in a Contracting State, may be taxed in that Contracting State. 5. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 such operation shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this Article shall 1 to 4 above, may be taxable only taxed in the Contracting State of in which the alienator is a residentthey 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 of a Contracting State from the alienation of sharesships, other than shares traded on aircraft, road or railway vehicles operated in international traffic by an enterprise of a Stock Exchange recognised by the other Contracting State, deriving at least three quarters or movable property pertaining to the operation of their value directly such ships, aircraft, road or indirectly from immovable property situated railway vehicles, shall be taxable only in that other Contracting State may be taxed in that other State. 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 the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property, other than that referred to such operation in paragraphs 1 to 4, shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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, 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 other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffic and movable property, pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State in which the place of head office (i. e. effective management) of the enterprise is situated. 4. Gains from the alienation of shares in a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that Contracting State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 representing a participation of 25 per cent in a company which is a resident of Contracting State may be taxed in that Contracting State. 6. Gains derived by a resident of a Contracting State from the alienation of shares, any property other than shares traded on a Stock Exchange recognised by that referred to in paragraphs 1 to 5 and arising in the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other Contracting State. 4. 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 such operation shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. Gains derived by a resident of a Contracting State from for the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such operation ships or aircraft shall be taxable only in 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 3 of this Article shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains derived by an individual who is a resident of a Contracting State from the alienation of any property shares or other than rights of a company which is a resident of the other Contracting State, as well as gains from the alienation of options or other financial instruments related to such shares or rights, may be taxed in that referred to in the preceding paragraphs of this Article shall be taxable other State, but only in the Contracting State of which if the alienator is has been a residentresident of that other State at any time during the five years immediately preceding the alienation of the shares, rights, options or financial instruments.

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, base may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on ships or aircraft operated in international traffic by an enterprise of a Stock Exchange recognised by the other Contracting State, deriving at least three quarters or movable property pertaining to the operation of their value directly such ships or indirectly from immovable property situated aircraft, shall be taxable only in that other Contracting State may be taxed in that other State. 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 the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property, other than that referred to such operation in paragraphs 1 to 4, shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. Gains derived by a resident of a Contracting State from the alienation of ships sh ips or aircraft operated in international traffic or movable property pertaining to the operation of such operation 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 of this Article, shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains Income or gains derived by a resident of a Contracting State from the alienation of any shares or comparable interests in a company, the assets of which consist wholly or principally of real property in the other than that Contracting State of a kind referred to in the preceding paragraphs of this Article shall 6, may be taxable only taxed in the Contracting State of which the alienator is a residentthat other State.

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 purposes of performing independent personal services, including such gains from the alienation of such a permanent establishment or of such a fixed basebase (alone or with the whole enterprise), may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 operation ships or aircraft shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of shares of the capital stock or any other shares of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting state may be taxed in that State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1,2, 3 and 4 shall be taxable only in the Contracting State of which the alienator is a resident. 56. Gains The provisions of paragraph 5 shall not affect the right of a Contracting State to levy according to its own law a tax on capital gains from the alienation of any property derived by a person who is a resident of the other than that referred to in the preceding paragraphs of this Article shall be taxable only in the Contracting State and has been a resident of which the alienator is a residentfirst- mentioned Contracting State at any time during the five years immediately preceding the alienation of the property.

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 sharesships or aircraft operated in international traffic, other than shares traded on a Stock Exchange recognised by or from movable property pertaining to the other Contracting State, deriving at least three quarters operation of their value directly such ships or indirectly from immovable property situated aircraft shall be taxable only in that other Contracting State may be taxed in that other State. 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 in international traffic or movable indirectly from immovable property pertaining to such operation shall be taxable only situated in the other Contracting State of which the alienator is a residentmay be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this Article 1, 2, 3 and 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 derived 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 of a Contracting State from the alienation of sharesships or aircraft operated in international tra fic, other than shares traded on a Stock Exchange recognised by or movable property pertaining to the other Contracting State, deriving at least three quarters operation of their value directly such ships or indirectly from immovable property situated aircraft sha l be taxable only in that other the Contracting State may be taxed in that other Stateof which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of ships shares or aircraft operated other corporate rights, of the capital stock of a company the property of which consists directly or indirectly principa ly (more than 50 percent of the aggregate value of assets owned by the company) of immovable property situated in international traffic or movable a Contracting State, may be taxed in that State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property pertaining other than that referred to such operation shall in paragraphs 1, 2, 3, 4 and 5, sha l be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 of a Contracting State from the alienation of shares, other than shares traded on ships or aircraft operated in international traffic by an enterprise of a Stock Exchange recognised by the other Contracting State, deriving at least three quarters or movable property pertaining to the operation of their value directly such ships or indirectly from immovable property situated aircraft, shall be taxable only in that other Contracting State may be taxed in that other State. 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 the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property, other than that referred to such operation in paragraphs 1, 2, 3 and 4, shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 an enterprise of a Contracting State from the alienation of ships, aircraft, railway or road vehicles operated in international traffic or movable property pertaining to the operation of such means of transport, shall be taxable only in that State. 34. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded in which there is substantial and regular trading on a Stock Exchange recognised by the other Contracting Statestock exchange, or comparable interests, deriving at least three quarters more than 50 per cent of their value directly or indirectly from immovable property situated in that the other Contracting State may be taxed in that other State. 45. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated any property, other than that referred to in international traffic or movable property pertaining to such operation paragraphs 1, 2, 3 and 4, shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 sharesships, other than shares traded on a Stock Exchange recognised by aircraft or containers (including trailers and related equipment for the transport of containers) operated in international traffic shall be taxable only in that Contracting State. The provisions of this paragraph, however, shall not apply if the containers or trailers and related equipment are used for transport solely between places within the other Contracting State, deriving at least three quarters . 4. Gains from the alienation of their value shares of the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in that other a Contracting State may be taxed in that other State. 45. Gains derived by from the alienation of shares other than those mentioned in paragraph 4 representing a participation of at least 10 per cent in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of ships or aircraft operated any property other than that referred to in international traffic or movable property pertaining to such operation paragraph 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 sharesship, other than shares traded on a Stock Exchange recognised aircraft, railway or road vehicles operated in international traffic by that enterprise or movable property pertaining to the other Contracting Stateoperation of such ships, deriving at least three quarters of their value directly aircraft, railway or indirectly from immovable property situated road vehicles shall be taxable only in that other Contracting State may be taxed in that other State. 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 in international traffic or movable indirectly from immovable property pertaining to such operation shall be taxable only situated in the other Contracting State of which the alienator is a residentmay be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 property, referred to in Article 6 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 together with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 operation ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains from the alienation of shares of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that Contracting State. For the purposes of this provision, immovable property pertaining to the industrial or commercial operation of such company shall not be taken into account. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 representing a participation of at least 10 per cent in a company which is a resident of a Contracting State may be taxed in that Contracting State. 6. Gains from the alienation of any property other than that referred to mentioned in the preceding paragraphs of this Article 1, 2, 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 a fixed base, may be taxed in that other State. 3. Gains derived by a resident an enterprise of a Contracting State operating ships, aircraft or road vehicles in international traffic from the alienation of sharesships, other than shares traded on a Stock Exchange recognised by aircraft or road vehicles operated in international traffic or movable property pertaining to the other Contracting Stateoperation of such ships, deriving at least three quarters of their value directly aircraft or indirectly from immovable property situated road vehicles, shall be taxable only in that other Contracting State may be taxed in that other State. 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 in international traffic or movable indirectly from immovable property pertaining to such operation shall be taxable only situated in the other Contracting State of which the alienator is a residentmay be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this Article 1, 2, 3 and 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 a fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on or corporate rights in a Stock Exchange recognised by company the other Contracting State, deriving at least three quarters assets of their value directly or indirectly from which consist mainly of immovable property situated in that other a Contracting State may be taxed in that other State. 4. 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 operation ships or aircraft shall be taxable only in the Contracting State of which the alienator is a residentthat State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 shares, other than shares traded on a Stock Exchange recognised by ships or aircraft operated in international traffic of movable property pertaining to the other Contracting State, deriving at least three quarters operation of their value directly such ships or indirectly from immovable property situated aircraft shall be taxable only in that other Contracting State may be taxed in that other State. 4. Gains derived by a resident of a Contracting State from the alienation of ships shares or aircraft operated comparable interests in international traffic a company, the assets of which consist wholly or movable principally or immovable property pertaining situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to such operation in paragraphs 1, 2, 3, 4 and 5 shall be taxable only in the Contracting State of which the alienator is a resident. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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 property, referred to in Article 6 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 a fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 operation ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains from the alienation of shares of a company, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. Gains from the alienation of interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains from the alienation of any property other than that referred to mentioned in the preceding paragraphs of this Article 1, 2, 3 and 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 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 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 arising from a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. Gains derived by a resident of a Contracting State from the alienation of capital asset being ships or aircraft operated operating in international traffic or movable property pertaining to the operation of such operation ships or aircraft by an enterprise of a Contracting state shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of shares of the capital stock of a company the property of which the alienator is consists directly or indirectly principally of immovable property situated in a residentContracting State may be taxed in that State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs of this Article 1,2,3 and 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 purposes of performing independent personal services, including such gains from the alienation of such a permanent establishment or of such a fixed basebase (alone or with the whole enterprise), may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 operation ships or aircraft shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 4. Gains from the alienation of shares of the capital stock or any other shares of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting state may be taxed in that State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3 and 4 shall be taxable only in the Contracting State of which the alienator is a resident. 56. Gains The provisions of paragraph 5 shall not affect the right of a Contracting State to levy according to its own law a tax on capital gains from the alienation of any property derived by a person who is a resident of the other than that referred to in the preceding paragraphs of this Article shall be taxable only in the Contracting State and has been a resident of which the alienator is a residentfirst- mentioned Contracting State at any time during the five years immediately preceding the alienation of the property.

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 of a Contracting State from the alienation of shares, other than shares traded on a Stock Exchange recognised by the other Contracting State, deriving at least three quarters of their value directly or indirectly from immovable property situated in that other Contracting State may be taxed in that other State. 4. 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 operation ships or aircraft, shall be taxable only in the that State. 4. Gains derived by a resident of a Contracting State from the alienation of which shares or other corporate rights deriving more than 50% of their value directly or indirectly from immovable property situated in the alienator is a residentother 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 of this Article shall be taxable only in the Contracting State of which the alienator is a resident.