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of <h1>Gains from Sale of Immovable Property and Shares May Be Taxed in the Property's Location State; Section Applies.</h1> Gains from the sale of immovable property by a resident of one Contracting State, when situated in the other Contracting State, may be taxed in the latter. Similarly, gains from shares deriving over 50% of their value from such immovable property may also be taxed in the other State. Gains from the sale of movable property tied to a permanent establishment or fixed base in the other State may be taxed there. However, gains from ships or aircraft in international traffic are taxable only in the resident's State. Other gains are taxable only in the State of the alienator's residence.
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