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<h1>Gains from Immovable Property Sales Taxable Where Located; Movable Property Gains Taxed Where Linked to Establishment</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. Gains from movable property linked to a permanent establishment or fixed base in the other Contracting State may also be taxed there. Gains from ships or aircraft operated in international traffic are taxable only in the alienator's resident State. Gains from shares deriving over 50% of their value from immovable property in the other State may be taxed there, while other share gains may be taxed in the company's resident State. All other property gains are taxable in the alienator's resident State.