Capital gains taxation: source State may tax disposals of immovable property, permanent establishment assets, and certain share sales.

Capital gains from alienation of immovable property located in the other Contracting State may be taxed by that State. Gains from disposal of movable property forming part of a permanent establishment or pertaining to a fixed base in the other State, including disposal of that permanent establishment or fixed base, may be taxed by that State. Gains from ships or aircraft operated in international traffic are taxable only in the State of enterprise residence. Shares whose value principally derives from immovable property may be taxed where the immovable property is situated; other share disposals may be taxed in the company's residence. Other gains are taxable only in the alienator's State of residence.

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