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<h1>Taxation Rules for Gains from Property and Shares Between Contracting States Explained: Key Provisions and Exceptions</h1> Gains from the alienation of immovable property by a resident of one Contracting State, situated in the other Contracting State, may be taxed in the latter. Gains from the alienation of business property of a permanent establishment or fixed base in the other state may also be taxed there. Gains from ships or aircraft in international traffic are taxable only in the alienator's resident state. Gains from shares mainly consisting of immovable property in a Contracting State may be taxed there, while other share gains may be taxed in the company's resident state. Other property gains are taxable only in the alienator's resident state.