Common use of GAINS FROM THE ALIENATION OF PROPERTY Clause in Contracts

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of 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 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) may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic and movable property, pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise is a resident. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property other than that referred to in paragraphs 1 to 4 and arising in the other Contracting State may be taxed in that other State.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of Article 6 and situated in the other Contracting State may be taxed in that other Statethe Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base may be taxed in the other State. However, gains derived by an enterprise of a Contracting State from the alienation of ships and aircraft operated in international traffic and movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic and movable property, pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise is a resident. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 54. Gains derived by a resident of a Contracting State from the alienation of any property property, other than that referred to those mentioned in paragraphs 1 to 4 1, 2 and arising 3 shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property property, referred to in paragraph 2 of Article 6 (Income from Immovable Property), 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 and by an enterprise of a Contracting State or gains from the alienation of movable property, property pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise is a residentthat State. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property other than that referred to mentioned in paragraphs 1 to 1, 2, 3 and 4 and arising shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of 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 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) may be taxed in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic and movable property, pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise enterprise is a resident. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property other than that referred to in paragraphs 1 to 4 and arising in the other Contracting State may be taxed in that other State.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to property, as defined in paragraph 2 of Article 6 and situated in the other Contracting State 6, may be taxed in that other Statethe Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) may be taxed in that the other State. 3. Gains However, gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic and movable property, property pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise enterprise is a resident. 43. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 54. Gains derived by a resident of a Contracting State from the alienation of any property or assets, other than that referred to those mentioned in paragraphs 1 to 4 1, 2 and arising 3 of this Article, shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to property, as defined in paragraph 2 of Article 6 and situated in the other Contracting State 6, may be taxed in that other Statethe Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or 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 by an enterprise of a Contracting State in international traffic and or movable property, property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the State of which the enterpise is a residentthat Contracting State. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of shares in a company, the assets of which consist wholly or principally or immovable property situated in the other Contracting State, may be taxed in that other State. 5. Gains from the alienation of shares other than those mentioned in paragraph 4 in a company which is a resident of a Contracting State may be taxed in that State. 6. Gains from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3, 4 and arising 5 shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of Article 6 (Income from Immovable Property) 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 derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic and or movable property, property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the State of which the enterpise is a residentthat State. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property property, other than that referred to those mentioned in paragraphs 1 to 1, 2, 3 and 4 and arising shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to property, as defined in paragraph 2 of Article 6 and situated in the other Contracting State 6, may be taxed in that other Statethe Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment establishment, which an enterprise of a Contracting State has in the other Contracting State or of movable property available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) may be taxed in that the other State. 3. Gains However, gains from the alienation of ships or aircraft operated by an enterprise of a Contracting State in international traffic and movable property, property pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise enterprise is a resident. 43. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 54. Gains derived by a resident of a Contracting State from the alienation of any property or assets, other than that referred to those mentioned in paragraphs 1 to 4 1, 2 and arising 3 of this Article, shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of Article 6 (Income from Immovable Property) 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 derived by an enterprise of a Contracting State from the alienation of ships or aircraft operated in international traffic and or movable property, property pertaining to the operation of such ships or aircraft aircraft, shall be taxable only in the State of which the enterpise is a residentthat State. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property property, other than that referred to those mentioned in paragraphs 1 to 1, 2, 3 and 4 and arising shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of Article 6 and situated in the other Contracting State may be taxed in that other Statethe Contracting State in which such property is situated. 2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal professional services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base may be taxed in the other State. However, gains derived by an enterprise of a Contracting State from the alienation of ships and aircraft operated in international traffic and movable property pertaining to the operation of such ships or aircraft, shall be taxable only in that other State. 3. Gains from the alienation of ships or aircraft operated in international traffic and movable property, pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise is a resident. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 54. Gains derived by a resident of a Contracting State from the alienation of any property property, other than that referred to those mentioned in paragraphs 1 to 4 1, 2, and arising 3 shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property property, referred to in paragraph 2 of Article 6 (Income from Immovable Property), 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 and by an enterprise of a Contracting State or gains from the alienation for movable property, property pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise is a residentthat State. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State State, may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property other than that referred to mentioned in paragraphs 1 to 1, 2, 3 and 4 and arising shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of Article 6 and situated in the other Contracting State may be taxed in that other State. 2. Gains derived by a resident of a Contracting State from the alienation of: a) shares, other than shares quoted on an approved Stock Exchange, deriving their value or the greater part of their value directly or indirectly from immovable property situated in the other Contracting State, or b) an interest in the assets of a person other than an individual where such assets consist principally of immovable property situated in the other Contracting State or of shares referred to in sub-paragraph (a) above, may be taxed in that other State. 3. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing 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 and movable property, pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise is a resident. 4. Gains from the alienation of shares ships, aircraft, railway or road transport vehicles operated in international transport by an enterprise of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State may or of movable property pertaining to the operation of the mentioned means of transport shall be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed taxable only in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property other than that referred to in paragraphs 1 to 1, 2, 3 and 4 and arising of this Article shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of 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 derived by an enterprise of a Contracting State operating ships or aircraft in international traffic from the alienation of ships or aircraft operated in international traffic and or movable property, property pertaining to the operation of such ships or aircraft aircrafts shall be taxable only in the State of which the enterpise is a resident. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 54. Gains derived by a resident of a Contracting State from the alienation of any shares, participations or comparable interests deriving more than 30 per cent of their value directly or indirectly from immovable property other than that referred to in paragraphs 1 to 4 and arising situated in the other Contracting State State, may be taxed in that other State. 5. Gains from the alienation of any property, other than that referred to in the preceding paragraphs, shall be taxable only in the Contracting State of which the alienator is a resident.

GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains derived by a resident of a Contracting State from the alienation of immovable property referred to in paragraph 2 of Article 6 (Income from Immovable Property) 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 and by an enterprise which is a resident of a Contracting State or gains from the alienation of movable property, property pertaining to the operation of such ships or aircraft shall be taxable only in the State of which the enterpise is a residentthat State. 4. Gains from the alienation of shares of the capital stock of a company, the principal property of which consists directly or indirectly principally of immovable property situated in a Contracting State may be taxed in that State. Gains from the alienation of an interest in a partnership or a trust, the property of which consists principally of immovable property situated in a Contracting State, may be taxed in that State. 5. Gains derived by a resident of a Contracting State from the alienation of any property property, other than that referred to those mentioned in paragraphs 1 to 1, 2, 3 and 4 and arising shall be taxable only in the other Contracting State may be taxed in that other Stateof which the alienator is a resident.