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 Article 6 and situated in the other Contracting State may be taxed in that other Contracting State. 2. Gains from the alienation of 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 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 Contracting 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 or property pertaining to the operation of such ships or 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 to 3, shall be taxable only in the Contracting State of which the alienator is a resident.
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Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
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 Article 6 and situated in the other Contracting State may be taxed in that other Contracting State.
2. Gains from the alienation of property other than immovable 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 such 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 the other Contracting 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 or property other than immovable 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 the preceding paragraphs 1 to 3, shall be taxable only in the Contracting State of which the alienator is a resident.
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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 Article 6 and situated in the other Contracting State as defined in Article 6 may be taxed in that other Contracting State.
2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State.
3. Gains derived by an enterprise which is 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 or assets, other than that those referred to in paragraphs 1 to 31, shall 2 and 3 of this Article, arising in a Contracting State, may be taxable only taxed in the that Contracting State of which the alienator is a residentState.
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Samples: Double Taxation Avoidance Agreement
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 Article 6 and situated in the other Contracting State as defined in Article 6 may be taxed in that other Contracting State.
2. Gains from the alienation of movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State or of movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or together with the whole enterprise) or of such a fixed base, may be taxed in that other Contracting State.
3. Gains derived by an enterprise which is 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 or assets, other than that those referred to in paragraphs 1 to 31, shall 2 and 3 of this Article, arising in a Contracting State, may be taxable only taxed in the that Contracting State of which the alienator is a residentState.
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