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of <h1>Gains from immovable property sales can be taxed in the property's location; shares over 50% in value follow suit.</h1> Gains from the sale of immovable property by a resident of one Contracting State, located in the other Contracting State, may be taxed in the latter. Movable property gains from a permanent establishment or fixed base in the other State may also be taxed there. Gains from ships or aircraft in international traffic are taxed only in the alienator's resident State. Shares deriving over 50% of their value from immovable property in a Contracting State may be taxed there. Other share gains are taxed in the company's resident State, while gains from other property are taxed in the alienator's resident State.
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