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of <h1>Gains from selling property may be taxed in the property's location; exceptions apply for international ships and aircraft.</h1> Gains from the sale of immovable property by a resident of one Contracting State, when situated in the other State, may be taxed in the latter. Gains from movable property linked to a permanent establishment or fixed base in the other State may also be taxed there. Gains from ships or aircraft in international traffic are taxed only in the resident's State. Gains from shares of a company primarily holding immovable property in a State may be taxed in that State. Other share gains may be taxed in the company's resident State. Gains not covered by these provisions are taxed per respective State laws.
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