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of <h1>Immovable property sale gains taxed where property is located; international transport gains taxed at resident state.</h1> Gains from the sale of immovable property by a resident of one Contracting State, when located in the other Contracting State, may be taxed in the latter. Gains from movable business property or a fixed base used for independent services in the other state may also be taxed there. Gains from international ships or aircraft operations are taxable only in the resident's state. Gains from shares in companies primarily owning immovable property in a state may be taxed in that state. Other share gains may be taxed in the company's resident state, while all other property gains are taxable in the alienator's resident state.
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