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 of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 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 of an enterprise 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 that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 2, and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

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

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains of an enterprise 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 that State. 4. Gains from the alienation of any property property, other than that referred to in the preceding paragraphs 1, 2 and 3, of this Article shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains Capital 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 Capital gains derived by a resident of a Contracting State from the alienation of movable property forming that formed part of the business property of a permanent establishment which an enterprise of a Contracting State has the alienator in the other Contracting State or is closely connected with the performance 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 servicesservices (to which Article 14 applies), by the alienator in that other State, including such capital gains arising from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed baseestablishment, may be taxed in that other State. 3. Gains Notwithstanding the provisions of an enterprise of a Contracting State paragraph 2, the capital gains resulting from the alienation of ships or aircraft operated the property of shares that constitute a share in international traffic or movable property pertaining to the operation capital of such ships or aircraft, shall be the company which is a resident of one of the two Contracting States are taxable only in that Statethe State in which the company exists. 4. Gains Capital gains derived from the alienation of any property other than that referred to in paragraphs 1, 2 and or 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 of derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3the preceding paragraphs, shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other 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 of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic by 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 State. 4. Gains from the alienation of shares of the capital stock of a company the property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that Contracting State. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 31 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 (establishment, alone or with the whole enterprise) , or of such fixed base, may be taxed in that the other Contracting State. 3. Gains of derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that Contracting State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

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

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains of derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 33 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 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 In the other Contracting State may be taxed in that other State. (2. ) Gains from the alienation of movable property forming part of o 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 of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, aircraft shall be taxable only in the Contracting State of which the alienator is a resident. (4) Gains from the alienation of any property other than that referred to in paragraphs (1),

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

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

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterprise) or of such fixed base, may be taxed in that other State. 3. Gains of an enterprise derived by a resident of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that State. 4. Gains derived by a resident of one of the Contracting States from the alienation of shares in a company, the assets of which consist wholly or principally of immovable property 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 the preceding paragraphs 1, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.

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

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

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

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, 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 of an enterprise of a Contracting State from the alienation of ships ships, boats, aircraft or aircraft road vehicle operated in international traffic or movable property pertaining to the operation of such ships ships, boats, aircraft or aircraftroad vehicle, shall be taxable only in the Contracting State in which the place of the effective management is situated. 4. Gains from the alienation of shares or other corporate rights in a company the assets of which directly or indirectly consist wholly or principally of immovable property situated in the other Contracting State may be taxed in that other State. 45. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 2, 3 and 3, 4 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in Article 6 and situated in the other Contracting State may be taxed in that other 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 State. 3. Gains of derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 and 3, 3 shall be taxable only in the Contracting State of which the alienator is a resident.

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to property, as defined in paragraph 2 of Article 6 and situated in the other Contracting State 6, may be taxed in that other Statethe 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 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 or of such fixed base (alone or together with the whole enterprise) or of such fixed base), may be taxed in that the other State. 3. Gains of an enterprise of a Contracting State However, gains from the alienation of ships or aircraft operated in international traffic or movable property pertaining to of the operation of such ships or aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that kind referred to in paragraphs 1, 2 and 3paragraph 3 of Article 23, shall be taxable only in the Contracting State in which such movable property is taxable according to the said Article. 3. Gains from the alienation of any property or assets, other than those mentioned in paragraphs 1 and 2 of this Article and paragraph 3 of Article 12, shall be taxable only in the 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 of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, 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 which is a resident of the other Contracting State may be taxed in that other State, if the resident holds or held at anytime during the previous two years more than 25% of capital in the company. 5. Gains from the alienation of any property other than that referred to in paragraphs 1, 2 2, 3 and 3, 4 shall be taxable only in the Contracting State of which the alienator is a resident.

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

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

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

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

CAPITAL GAINS. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property property, referred to in Article 6 and 6, 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 of derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or and aircraft, shall be taxable only in that State. 4. Gains from the alienation of any property other than that referred to in paragraphs paragraph 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 of an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic or movable property pertaining to the operation of such ships or aircraft, aircraft shall be taxable only in that Statethe Contracting State of which the enterprise is a resident. 4. Gains from the alienation of any property other than that those referred to in paragraphs 11,2, 2 and 3, shall be taxable only in the Contracting State of which the alienator is a resident.