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of <h1>Gains from selling foreign immovable property or shares in entities with such assets may be taxed in that state.</h1> Gains from the sale of immovable property by a resident of one Contracting State, situated in the other Contracting State, may be taxed in the latter. Gains from movable property tied to a permanent establishment or fixed base in the other State can also be taxed there. Gains from ships or aircraft in international traffic are taxable only in the State of effective management. Gains from shares in entities primarily holding immovable property in a State may be taxed in that State, while other shares are taxed in the State of residence. Other property gains are taxable only in the alienator's residence State.
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