Alienation of property: taxing rights allocated to state where property or business presence is located, with specific exceptions.

Immovable property situated in a Contracting State may be taxed by that State on alienation by a resident of the other State. Property forming part of the business property of a permanent establishment or pertaining to a fixed base in the other State may be taxed by that other State when alienated, including alienation of the permanent establishment or fixed base. Ships or aircraft operated in international traffic are taxable only in the enterprise's State of residence. Share disposals are taxed by reference to whether the company's assets consist principally of immovable property situated in a Contracting State or to the company's State of residence. Domestic rules on other capital gains remain unaffected.

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