GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains from the alienation of immovable property, as defined in paragraph 2 of Article 6, may be taxed in the 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 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 from the alienation of ships and aircraft operated in international traffic and of movable property pertaining to the operation of such ships and aircraft shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. 3. Gains from the alienation of shares of stock issued by a company which is a resident of a Contracting State may be taxed in that Contracting State. 4. Gains from the alienation of any property other than those mentioned in paragraphs 1, 2 and 3 shall be taxable only in the Contracting State of which the alienator is a resident.
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Samples: Double Taxation Avoidance Agreement, Double Taxation Agreement, Double Taxation Agreement
GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains from the alienation of immovable property, as defined property referred to in paragraph 2 of Article 66 (Income from Immovable Property), may be taxed in the 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 professional 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, base may be taxed in the that other State.
3. However, gains Gains from the alienation of ships and or aircraft operated in international traffic and of or movable property pertaining to the operation of such ships and aircraft or aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
34. Gains from the alienation of shares of stock issued by a company the property of which is a resident consist directly principally of immovable property situated in a Contracting State may be taxed in that Contracting State.
45. Gains from the alienation of any property property, other than those that mentioned in paragraphs 1, 2 2, 3 and 3 4 shall be taxable only in the Contracting State of which the alienator is a resident.
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Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
GAINS FROM THE ALIENATION OF PROPERTY. 1. Gains from the alienation of immovable property, as defined property referred to in paragraph 2 of Article 66 (Income from Immovable Property), may be taxed in the 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 professional 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, base may be taxed in the that 1 other State.
3. However, gains Gains from the alienation of ships and or aircraft operated in international traffic and of or movable property pertaining to the operation of such ships and aircraft or aircraft, shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated.
34. Gains from the alienation of shares of stock issued by a company the property of which is a resident consist directly principally of immovable property situated in a Contracting State may be taxed in that Contracting State.
45. Gains from the alienation of any property property, other than those that mentioned in paragraphs 1, 2 2, 3 and 3 4 shall be taxable only in the Contracting State of which the alienator is a resident.
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