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of <h1>Gains from foreign property sales may be taxed where property is located; international transport gains taxed at residence.</h1> Gains from the sale of immovable property by a resident of one contracting state situated in another may be taxed in the latter. Gains from movable property tied to a business 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 alienator's resident state. Gains from shares or rights deriving significant value from immovable property in the other state may be taxed there. Other gains from shares in a company resident in the other state may also be taxed there. All other property gains are taxable in the alienator's resident state.
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