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 from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 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 property, referred to in Article 6 6, and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists principally, directly or indirectly from indirectly, of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to mentioned in paragraphs 1, 2, 3, 4 and 5, 5 of this Article and paragraph 3(b) of Article 12 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company, the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in 4, forming part of a participation of at least 10 per cent of the capital stock of 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 mentioned in paragraphs 1, 2, 3, 4 and 5, 5 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by an enterprise which is a resident of a Contracting State from the alienation of ships, aircraft or road vehicle operated in international traffic or property pertaining to the operation of such ships, aircraft or road vehicle, shall be taxable only in that Contracting State. 4. Gains from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 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 State, or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, boats engaged in inland waterways transport or movable property pertaining to the operation of such ships ships, aircraft or aircraft boats, shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent percent of their value directly or indirectly from immovable property situated in the other Contracting State or any other right pertaining to such immovable property 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 15 per cent in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 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 establishment(alone or with the whole enterprise) or enterprise)or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of in which the alienator place of head office of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, shall I to 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 a fixed base, may be taxed in that other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffic, or traffic and movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived are received by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State or any other right pertaining to such immovable property may only be taxed in that other State. 54. Gains from the alienation of shares in the capital of a company, the assets of which consist mainly, directly or indirectly, of immovable property situated in a Contracting State, may be taxed in that Contracting State. 5. Gains derived from the alienation of shares, other than those mentioned in paragraph 4 and which represent a participation of 25 per cent in a company which is a resident of a Contracting State State, may be taxed in that Contracting State. 6. Gains which a resident of a Contracting State derives from the alienation of any property other than that referred to mentioned in paragraphs 11 to 5 above, 2, 3, 4 and 5, shall may be taxable only taxed in the other Contracting State of which the alienator is a residentState, if those gains are derived therefrom.

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 establishment(alone or together with the whole enterprise) or enterprise)or of such a fixed base, may be taxed in that other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of in which the alienator place of head office of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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, 2, 3, 4 and 5, shall 1 to 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 a fixed base, may be taxed in that other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that Contracting State. 4. Gains from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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, 2, 3, 4 and 1 to 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 from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of in which the alienator place of head office of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares in the capital of a company, the assets of which consist mainly, directly or indirectly, of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived from the alienation of shares, other than those mentioned in paragraph 4 and which represent a participation of 25 per cent in a company which is a resident of a Contracting State State, may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, 5 shall be taxable only in the Contracting State of in which the alienator transferred property is a residentsituated.

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 from the alienation of ships or aircraft operated in international traffic, traffic by enterprises of a Contracting State or gains from the alienation of movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the Contracting State of which the alienator is a residentthat State. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in of the capital stock of a company the property of which is a resident consists directly principally of immovable property situated in a Contracting State may be taxed in that State. 65. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 51 to 4, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a residentthat State. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 int that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 5, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. 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. 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. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. 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 StateState in which the company issuing shares is resident. 6. 6. Gains from the alienation of any property other than that referred to in paragraphs 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 property, referred to in Article 6 6, and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or of movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists, directly or indirectly from indirectly, principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from for the alienation of shares other than those mentioned in paragraph 4 of the capital stock of a company forming part of a participation of at least 10 per cent in a company which is a resident of a Contracting State may be taxed in that Contracting State. 6. Gains from the alienation of any property other than that referred to mentioned in paragraphs 1, 2, 3, 4 and 5, 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 together with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State. 3. Gains from the alienation of ships ships, aircraft or aircraft land vehicles operated in international traffic, traffic or movable property pertaining to the operation of such ships ships, aircraft or aircraft land vehicles, shall be taxable only in the that Contracting State of in which the alienator place of head office of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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, 2, 3, 4 and 1 to 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, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a residentthat State. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 the preceding paragraphs 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 a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the that Contracting State of which the alienator is a residentState. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 5, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains derived by an enterprise of a Contracting State from the alienation of ships or aircraft or road vehicle operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft or road vehicle, shall be taxable only in the that Contracting State of which the alienator is a residentState. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 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 property, referred to in Article 6 6, and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or of movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists, directly or indirectly from indirectly, principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 of the capital stock of a company forming part of a participation of at least 10 per cent in a company which is a resident of a Contracting State may be taxed in that Contracting State. 6. Gains from the alienation of any property other than that referred to mentioned in paragraphs 1, 2, 3, 4 and 5, 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 together with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffictraffic and movable property, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of in which the alienator enterprise is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 25 per cent in a company which is a resident of a Contracting State may be taxed in that Contracting State. 6. Gains derived by a resident of a Contracting State from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 1 to 5 and 5, shall be taxable only arising in the other Contracting State of which the alienator is a residentmay be taxed in that 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 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, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the that Contracting State of in which the alienator place of effective management of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value directly or indirectly from immovable property situated in the other Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, 5 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the that Contracting State of which the alienator is a residentState. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other Contracting State. 5. Gains Xxxxx 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 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 together with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the Contracting State of in which the alienator place of head office (i. e. effective management) of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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, 2, 3, 4 and 5, 5 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such a fixed base, may be taxed in that other State. 3. Gains from the alienation of ships ships, aircraft or aircraft road vehicle operated in international traffic, or traffic and movable property pertaining to the operation of such ships ships, aircraft or aircraft road vehicle shall be taxable only in the Contracting State of in which the alienator place of head office of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 at least 25 per cent in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1to 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, or traffic [or] of movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the Contracting State of which the alienator is a resident.that State 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent or comparable interests in a company, the assets of their value directly which consist wholly or indirectly from principally of immovable property situated in the other Contracting State or any other right pertaining to such immovable property State, may be taxed in that other State. 5. Gains from the alienation of shares shares, other than those mentioned in paragraph 4 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, 2, 3, 4 and 5, 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 also 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 also 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, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a residentthat State. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, 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 a fixed base, may be taxed in that other State. 3. Gains derived by an enterprise which is a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the that Contracting State of which the alienator is a residentState. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 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 article 6 and situated situate in the other Contracting State may also 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 basebas, may also 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, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a residentthat State. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company company, which is a resident of a Contracting State State, may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 11,2,3,4, 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 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 along or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property (including containers and related equipment) pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company, the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to mentioned in the preceding paragraphs 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 a fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, shall 5 may be taxable only taxed in accordance with the taxation laws of the respective Contracting State of which the alienator is a residentStates.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such 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, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a residentthat State. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, 1 to 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 together with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft by an enterprise of a Contracting State shall be taxable only in the Contracting State of which the alienator is a residentthat State. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 StateContracting state. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 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 establishment(alone or with the whole enterprise) or enterprise)or of such a fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft by an enterprise of a Contracting State shall be taxable only in the that Contracting State of which the alienator is a residentState. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, shall 1 to 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 from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State State, or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the Contracting State of in which the alienator place of effective management of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 at least 25 per cent in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in the preceding paragraphs 1, 2, 3, 4 and 5, 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 from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft by an enterprise of a Contracting State shall be taxable only in the that Contracting State of which the alienator is a residentState. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other Contracting State. 5. Gains Xxxxx 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 5, shall 1 to 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 from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. FBR, Government of Pakistan 4. Gains from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains Xxxxx from the alienation of shares other than those mentioned in paragraph 4 representing a participation of 25 per cent or more 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, 2, 3, 4 paragraph 1,2,3,4 and 5, 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 together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by an enterprise which is a resident of a Contracting State from the alienation of ships, aircraft, train and auto transport vehicles operated in international traffic or movable property pertaining to the operation of such ships, aircraft, train, and auto transport vehicles, shall be taxable only in that State. 4. Gains from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains Xxxxx 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 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 together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in 4, forming part of a participation of at least 10 per cent. of the capital stock of 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 mentioned in paragraphs 1, 2, 3, 4 and 5, 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 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.such 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of in which the alienator place of effective management of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capita! stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 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 a fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, traffic or movable property pertaining to the operation of such ships or aircraft shall be taxable only in the Contracting State of in which the alienator place of head office or of effective management of the enterprise is a residentsituated. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property 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 State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1, 2, 3, 4 and 1 to 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 together with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic, or movable property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the Contracting State of which the alienator is a resident. 4. Gains derived by a resident of a Contracting State from the alienation of shares deriving more than 50 per cent of their value the capital stock of a company the property of which consists directly or indirectly from principally of immovable property situated in the other a Contracting State or any other right pertaining to such immovable property may be taxed in that other State. 5. Gains from the alienation of shares shares, other than those mentioned in paragraph 4 in of 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 mentioned in paragraphs 1, 2, 3, 4 and 5, 5 shall be taxable only in the Contracting State of which the alienator is a resident.