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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 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 fixed base, may be taxed in that other State. 3. Gains derived by that an enterprise of a Contracting State that operates ships or aircraft in international traffic derives from the alienation of such ships or aircraft operated in international traffic by that enterprise aircraft, or of movable property pertaining to the operation of such ships or aircraft 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, of the capital stock of a company, the asset value of which consists directly or indirectly of at least 75 per cent from immovable property situated in a company the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property property, other than that referred to in paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft 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 in traded on a company the assets recognised Stock Exchange, deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 to 4 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Statethe 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 shares, other than shares in traded on a company the assets recognized stock exchange, deriving more than 75 per cent of which consist mainly their value directly or indirectly of immovable property referred to in Article 6 and 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 paragraphs 1 to 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 an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 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, 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraft boats, shall be taxable only in that Statethe 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 shares in a company the assets or comparable interests deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 paragraphs 1 to 4 (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 Party from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State Party may be taxed in that other StateParty. 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 Party has in the other Contracting State Party or of movable property pertaining to a fixed base available to a resident of a Contracting State Party in the other Contracting State Party 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 StateParty. 3. Gains derived by a resident of a Contracting Party from the alienation of shares or comparable interests in a company, the assets of which consist wholly or principally of immovable property situated in the other Contracting Party, may be taxed in that other Party. 4. Gains derived by an enterprise of a Contracting State Party from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other StateParty. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3 and 4 shall be taxable only in the Contracting State Party 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 or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property or assets, other than that those referred to in paragraphs 1 to 4 1, 2 and 3 of this Article and paragraph 7 of Article 12, 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 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Statethe Contracting State in which the place of head office of the enterprise is situated. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 representing a participation of at least 25 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 in paragraphs 1 to 4 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 immova- ble 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 prop- erty 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 perform- ing 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 or aircraft operated in international traffic by that enterprise or from movable property pertaining to the operation of such ships or aircraft shall be taxable tax- able only in that Statethe 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 shares in or of a company the assets comparable interest deriving more than 50% of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property property, other than that referred to in paragraphs 1 to 4 para- graphs 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 properly 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 perforating 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 or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets shares, deriving more than 50 per cent of which consist mainly of their value directly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. The provisions of this paragraph shall not apply if the immovable property is used in a manufacturing activity carried on for a continuous period of at least five years. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of a company the assets company, other than shares traded on a recognised stock exchange, deriving more than 50 per cent of which consist mainly of their value from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1 to 4 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 or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property or assets, other than that those referred to in paragraphs 1 to 4 1, 2 and 3 of this Article and paragraph 3 of Article 12, 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 an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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, or of an interest in a company the assets partnership, trust or estate deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property property, other than that referred to in paragraphs 1 to 4 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 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 other Contracting State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 in a company the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 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 immov- able 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 availa- ble 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 of an enterprise of a Contracting State from the alienation of ships or aircraft air- craft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets proper- ty of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in the pre- ceding paragraphs 1 to 4 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 or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company company, the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 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 that an enterprise of a Contracting State that operates ships or aircraft in international traffic derives from the alienation of such ships or aircraft operated in international traffic by that enterprise or of movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and 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 paragraphs 1 to 1, 2, 3 and 4 shall be taxable only that arise in the other Contracting State of which the alienator is a residentmay be taxed in that 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 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 or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 1, 2 and 3 of this Article and paragraph 3 of Article 12, 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international 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 derived by a resident of a Contracting State from the alienation of shares or comparable interests in a company company, the assets of which consist mainly wholly or principally of immovable property referred to in Article 6 and situated in the other Contracting State State, may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3, 4 and 6 shall be taxable only in the Contracting State of which the alienator is a resident. 6. The provisions of paragraph 5 shall not affect the right of each of the Contracting States to levy according to its own law a tax on gains from the alienation of shares or rights in a company, the capital of which is wholly or partly divided into shares and which under the laws of that State is a resident of that State, derived by an individual who is a resident of the other Contracting 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 5 situated in the other Contracting State may be taxed in that other Statethe Contracting State in which such property is situated. 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 an enterprise of a Contracting State from the alienation of ships or aircraft ships, aircraft, railway and road vehicles operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft means of transport shall be taxable only in that 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 shares or comparable interests in a company company, the assets of which consist mainly wholly or principally of immovable property referred to in Article 6 and situated in the other Contracting State State, may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 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 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 other Contracting State. However, this provision shall not apply to the gains derived from such alienation of property to which the provisions of paragraph 6 of Article 12 apply. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international 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 derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a 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 to 4 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 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 an enterprise of a Contracting State from the alienation of ships ,aircraft or aircraft road vehicles operated in international traffic by that enterprise or movable property pertaining to the operation of such ships ships, aircraft or aircraft road vehicles shall be taxable only in that Statethe Contracting State in which the enterprise operating the ship, aircraft or road vehicles is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 shall 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 from the alienation of ships, aircraft, railway or road transport vehicles operated in international traffic by an enterprise of a Contracting State from the alienation or of ships or aircraft operated in international traffic by that enterprise or 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 derived by a resident of a Contracting State from the alienation of shares in a company the assets company, which is a resident of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State State, other than shares quoted on an approved Stock Exchange, may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 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 territory from the alienation of immovable property referred to in paragraph 2 of Article 6 and situated in the other Contracting State territory may be taxed in that other Stateterritory. 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 territory has in the other Contracting State territory, or of movable property pertaining to a fixed base available to a resident of a Contracting State territory in the other Contracting State territory for the purpose purposes 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 Stateterritory. 3. Gains derived by an enterprise of a Contracting State territory from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Stateterritory. 4. Gains derived by a resident of a Contracting State territory from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State territory may be taxed in that other Stateterritory. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3 and 4 shall be taxable only in the Contracting State territory 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Statethe Contracting State of which the enterprise is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets or comparable interests deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of a participation of 25 percent or more in 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 in paragraphs 1 to 1, 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 immov- able property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Contracting State. 2. Gains derived by a resident of a Contracting State from the alienation of movable shares or other comparable interests in a company or of interests in a partnership or trust may be taxed in the other Contracting State where the shares or the interests derive at least 50 per cent of their value directly or indirectly from immovable property forming referred to in Article 6 and situated in that other Contracting State. 3. Gains from the alienation of any property, other than immovable property, form- ing 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 servicesState, including such gains from the alienation al- ienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base), may be taxed in that other Contracting State. 34. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated by that enterprise in international traffic by that enterprise or movable property any property, other than immovable 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 in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 pre- ceding paragraphs 1 to 4 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 an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Contracting State. (4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property property, other than that referred to in paragraphs 1 to 4 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 (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 other Contracting State. (3. ) Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in a Contracting State in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships ships, or aircraft aircraft, shall be taxable only in that Statethe 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 shares of the capital stock of a company, or of an interest in a company partnership, trust or estate, the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other Contracting State. For the purposes of this paragraph, "principally" in relation to ownership of immovable property means the value of such immovable property exceeding 50 % of the aggregate value of all assets owned by the company, partnership or trust. (5. ) Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 (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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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, 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 of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 to 4 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 an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 to 4 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 derived by a resident of a Contracting State from the alienation of shares or of a comparable interest deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State. 3. 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. 34. Gains derived by an enterprise of a Contracting State operating ships or aircraft in international traffic from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property property, other than that referred to in paragraphs 1 to 4 1, 2, 3 and 4, shall be taxable only in the Contracting State of which the alienator is a resident, if that resident is the beneficial owner of such capital gains.

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 an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or from movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 90 percent of which consist mainly of their value, directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State (other than shares listed on the stock exchange of their Contracting State) may be taxed in that other StateState provided the resident owns, directly or indirectly, a minimum of 10 percent of the issued shares. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of property forming part of the business property of an enterprise and consisting of ships or aircraft operated by that enterprise in international traffic by that enterprise or of movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Statethe 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 shares or other interests in a company the assets company, which is a resident of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State State, may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 in or of a company the assets comparable interest deriving more than 50 percent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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 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 other Contracting State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets company, deriving more than 50 per cent of which consist mainly of their value directly from immovable property referred to in Article 6 and 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 paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares of the capital stock of a company, or of an interest in a company partnership or trust, the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in preceding paragraphs 1 to 4 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 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 shall 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 property, as defined in Article 6 and situated in the other Contracting State 6, may be taxed in that other Statethe Contracting State in which such property is situated. 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Statethe Contracting State of which the enterprise is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests in a company company, the assets of which consist mainly wholly or principally of immovable property referred to in Article 6 and situated in the other Contracting State State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 representing a participation of more than 22.5 percent 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 in paragraphs 1 to 1, 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 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, base may be taxed in that other Contracting State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships ships, aircraft or aircraft road vehicles operated in international traffic by that enterprise or movable property pertaining to the operation of such ships ships, aircraft or aircraft road vehicles shall be taxable only in that Statethe 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 shares in a company the assets or comparable interests deriving more than 50% of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived from the alienation of ships, aircraft or road vehicles operated in international traffic by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships ships, aircraft or aircraft road vehicles shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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 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, base may be taxed in that other Contracting State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships ships, aircraft or aircraft road vehicles and railway operated in international traffic by that enterprise or movable property pertaining to the operation of such ships ships, aircraft or aircraft road vehicles and railway shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares or other corporate rights in a company the assets of which directly or indirectly consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 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 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 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that an enterprise of a Contracting State or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares of the capital stock of a company the property of which consists directly or indirectly of immovable property and of an interest in a company partnership the assets of which consist mainly consists principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other State. 5. Gains from the alienation of shares of a company and an interest in a partnership other than those mentioned in paragraph 4, may be taxed in the Contracting State of which the company or partnership is resident. 6. Gains from the alienation of any property other than that referred to mentioned in paragraphs 1 to 1, 2, 3, 4 and 5, shall be taxable only in the Contracting State of which the alienator is a residentresident provided that those gains are subject to tax in that Contracting 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 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 other Contracting State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, boats engaged in inland waterway transport or movable property pertaining to the operation of such ships ship, aircraft or aircraft boat, shall be taxable only in that Statethe 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 shares or other corporate rights, in a company or any other legal entities, the assets of which directly or indirectly consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 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 by a resident of a Contracting State from the alienation of shares in a company, other than shares that are traded, regularly and in substantial volumes, on a Stock Exchange, or other comparable interests in a partnership or similar structure, where more than 50 per cent of the asset value of that company, partnership or structure derives directly or indirectly from immovable property situated in the other Contracting State, may be taxed in that other State. 3. 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 servicesState, 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. 34. Gains derived by that an enterprise of a Contracting State that operates ships or aircraft in international traffic derives from the alienation of such ships or aircraft operated in international traffic by that enterprise aircraft, or from movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or from movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets or other corporate rights deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property property, other than that referred to in paragraphs 1 to 4 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 paragraphs 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 derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly, directly or indirectly, of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 3. 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. 34. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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 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 of with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of arising from a Contracting State from the alienation of capital asset being ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft by an enterprise of a Contracting State shall be taxable only in that Statethe 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 shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3 and 4 shall be taxable only in the Contracting State of which the he 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that an enterprise of a Contracting State, or movable property pertaining to the operation of such ships ships, or aircraft shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of any property property, other than that referred to in paragraphs 1 to 4 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 an enterprise of a Contracting State from the alienation of ships or aircraft or road vehicles operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships ships, aircraft or aircraft road vehicles, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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, may be taxed 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, 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 shares or similar rights in a company, or of an interest in a partnership, trust or estate, the assets of which consist principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation sale, exchange or other disposition, directly or indirectly, of shares or similar rights in a company the assets company, other than those mentioned in paragraph 4, which is a resident of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State State, may be taxed in that other State. 56. Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 the 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 State. 2. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State may be taxed in that other State. 3. 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 or aircraft operated in international traffic by that enterprise 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 operating ships or aircraft in international traffic from the alienation of shares ships or aircraft operated in a company international traffic or movable property pertaining to the assets operation of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may such ships or aircraft, shall be taxed taxable only in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3 and 4 of this Article, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains Profits or gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains Profits or gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining pertains 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 profits or gains from the alienation of such a that 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 Profits or gains from the alienation of ships or aircraft aircraft, road and railway and road vehicle operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft transports, shall be taxable only in that Statethe Contracting State of which the enterprise is resident. 4. Gains Profits or gains derived by a resident of a Contracting State from the alienation of shares or other corporate rights in a company company, the assets of which directly or indirectly consist mainly wholly or principally of immovable property referred to in Article 6 and 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 paragraphs 1 to 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 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 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 (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships ships, aircraft or aircraft land vehicles operated in international traffic by that enterprise or movable property pertaining to the operation of such ships ships, aircraft or aircraft land vehicles shall be taxable only in that Statethe Contracting State in which the enterprise is registered and having its headquarters (i.e. effective management). 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a 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 property, other than that referred to mentioned in paragraphs 1 to 1, 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 immov- able 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 per- forming 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation opera- tion of such ships or aircraft shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in or of a company the assets comparable interest deriving more than 50 percent of which consist mainly of their value directly or indi- rectly from immovable property referred to in Article 6 and 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 paragraphs 1 to 4 para- graphs 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 fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of any equipment used in the other Contracting State may be taxed in that other Contracting State provided that the equipment is disposed of to a resident of that other Contracting State. 4. Gains derived by an enterprise of a Contracting State from the alienation of ships or and aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft traffic, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by of an enterprise of a Contracting State from the alienation a lienation of ships or aircraft operated in international traffic by that enterprise 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 shares or similar rights in a company, or of an interest in a partnership, trust or estate, the assets of which consist principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation sale, exchange or o ther disposition, directly or indirectly, of shares or similar rights in a company the assets company, other than those mentioned in paragraph 4, which is a resident of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State State, may be taxed in that other State. 56. Gains from the alienation of any property pr operty other than that referred to in paragraphs 1 to 4 the 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 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 enterprise)or of such fixed base, base may be taxed in that other State. 3. Gains derived by an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that StateState . 4. Gains derived by a resident of a Contracting State from the alienation of shares or other corporate rights in a company the assets of which directly or indirectly consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or from movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets or comparable interests deriving more than 50% of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 paragraphs 1 to 1, 2, 3 and 4 shall be taxable only in the Contracting State of which the alienator is a resident.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, base may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft shall be taxable only in that Contracting State. 4. Gains derived by a resident of a Contracting State from the alienation of shares or other corporate rights in a company company, the assets of which directly or indirectly consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 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 formi ng 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 de rived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international 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 derived by a resident of a Contracting State from the alienation of shares or other corporate rights in a company the assets of which consist consist, directly or indirectly, mainly of immovable property referred to in Article 6 and 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 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 For the purposes of paragraph 1, gains from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State shall include gains from the alienation of shares or other rights in a company or other legal entity, or of an interest in a partnership or under a trust, the greater part of the assets of which consist, directly or indirectly, of immovable property situated in that other Contracting State or of any other right pertaining to such immovable property. 3. Gains, other than those dealt with in paragraph 2 of this Article, 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. 34. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a the Contracting State from in which the alienation place of shares in a company effective management of the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Stateenterprise is situated. 5. Gains from the alienation of any property property, other than that referred to in the preceding paragraphs 1 to 4 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 an enterprise a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the Contracting State in which the place of head office or 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. 45. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 shall be taxable only and arising in the other Contracting State of which the alienator is a residentmay be taxed in that 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 derived by a resident of a Contracting State from the alienation of: (a) shares, other than shares in which there is substantial and regular trading on an approved Stock Exchange, deriving their value or the greater part of their value directly or indirectly from immovable property situated in the other Contracting State, or (b) an interest in the assets of a person other than an individual where such assets consist principally of immovable property situated in the other Contracting State or shares referred to in subparagraph (a) above, may be taxed in that other State. 3. 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. 34. Gains derived from the alienation of ships, aircraft or road transport vehicles operated in international transport by an enterprise of a Contracting State from the alienation or of ships or aircraft operated in international traffic by that enterprise or 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 derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft aircraft, operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares or other corporate rights in a company company, the assets of which consist mainly consist, directly or indirectly, wholly or principally, of immovable property referred to in Article 6 and situated in the other Contracting State State, may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares or comparable interests in a company company, the assets of which consist mainly consists wholly or principally of immovable real property referred to in Article 6 and situated in the other Contracting State of a kind referred to in Article 6, may be taxed in that other State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3 and 4 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aricraft, shall be taxable only in that Statethe Contracting State of which the enterprise is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets or comparable interests deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 5. Gains from the alienation of a participation of 25 percent or more in 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 in paragraphs 1 to 1, 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraft boats, shall be taxable only in that Statethe 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 shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other State. 5. Gains from the alienation of any property shares other than that referred those mentioned in the previous paragraph may be subject to in paragraphs 1 to 4 shall be taxable only taxes in the Contracting State of which where the alienator is a residentgain originated.

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 servicesservic es, 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 of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 to 4 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 the Contracting State in which such property is situated. 2. Gains derived by a resident of a Contracting State from the alienation of: a) shares, other than shares quoted on an approved stock exchange deriving their value or the greater part of their value directly or indirectly from immovable property situated in the other Contracting State, or b) a contribution in a partnership the assets of which consist principally of immovable property situated in the other Contracting State or of shares referred to in subparagraph (a) above, may be taxed in that other State. 23. 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 servicesState, 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. 34. Gains derived by an enterprise of a Contracting State from the alienation of ships or ships, aircraft and road vehicles operated in international traffic by that enterprise or movable property pertaining to the operation of such ships or aircraft means of transport shall be taxable only in that State. 4. Gains derived by a resident of a the Contracting State from in which the alienation place of shares in a company effective management of the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other Stateenterprise is situated. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 in a company the assets or comparable interests deriving more than 50 per cent of which consist mainly of their value directly or indirectly from immovable property referred to in Article 6 and 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 paragraphs 1 to 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 fixed base, may be taxed in that other State. 3. Gains derived by an enterprise a resident of a Contracting State from the alienation of ships aircraft or aircraft road vehicles operated in international traffic by that enterprise traffic, or movable property pertaining to the operation of such ships aircraft or aircraft road vehicles shall be taxable only in that State. 4. Gains derived by a resident of a Contracting State from the alienation of shares in a company the assets of which consist mainly of immovable property referred to in Article 6 and 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 paragraphs 1 to 4 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 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 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 (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships ships, aircraft or aircraft land vehicles operated in international traffic by that enterprise or movable property pertaining to the operation of such ships ships, aircraft or aircraft land vehicles shall be taxable only in that Statethe Contracting State in which the enterprise is registered and having the headquarter (i.e. effective management). 4. Gains derived by a resident of a Contracting State from the alienation of shares in of the capital stock of a company the assets property of which consist mainly consists directly or indirectly principally of immovable property referred to in Article 6 and situated in the other a Contracting State may be taxed in that other State. 5. Gains from the alienation of any property shares, other than those mentioned in paragraph 4, in a company which is a resident of a Contracting State may be taxed in that referred to State. 6. Gains from the alienation of any property, other than mentioned in paragraphs 1 to 1, 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 of this Convention and situated in the other Contracting State may be taxed in that other State. (2. ) Gains derived by a resident of a Contacting State from the alienation of: (a) shares, other than shares quoted on an approved Stock Exchange, deriving their value or the greater part of their value directly or indirectly from immovable property situated in the other Contracting State, or (b) an interest in a partnership or trust the assets of which consist principally of immovable property situated in the other Contracting State, or of shares referred to in sub-paragraph (a) above, may be taxed in that other State (3) 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 performng 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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 ships or aircraft operating in international traffic by an enterprise of a company the assets of which consist mainly of immovable property referred to in Article 6 and situated in the other Contracting State may or movable property pertaining to the operation of such ships or aircraft, shall be taxed taxable only in that other Contracting State. (5. ) Gains from the alienation of any property other than that referred to in paragraphs 1 to 4 shall be taxable only in the Contracting State of which the alienator is a resident.(1),(2),

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 an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by that enterprise 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 or comparable interests in a company company, the assets of which consist mainly wholly or principally of immovable property referred to in Article 6 and situated in the other Contracting State Sate, may be taxed in that other State. 4. Gains from the alienation of shares other than those mentioned in paragraph 3 in a company which is a resident of a Contracting Sate maybe taxed in that State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3, and 4 shall be taxable only in the Contracting State Sate of which the alienator is a resident.