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of <h1>Gains from the sale of immovable property may be taxed in the state where the property is located.</h1> Gains from the sale of immovable property by a resident of one Contracting State, if situated in the other Contracting State, may be taxed in that other State. Gains from movable property tied to a business or fixed base in the other Contracting 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 primarily consisting of immovable property in a Contracting State may be taxed there, while other shares and property gains are taxable only in the alienator's resident State.
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