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of <h1>Gains from selling property may be taxed in the property's location; specific rules apply for shares and international traffic.</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 related to a permanent establishment or fixed base in the other Contracting State may also be taxed there. Gains from ships or aircraft in international traffic are taxed only in the State of effective management. Gains from shares deriving over 50% of their value from immovable property in the other State may be taxed there. Other share gains are taxed in the company's resident State, while other property gains are taxed in the alienator's resident State.
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