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of <h1>Article 13: Rules for taxing gains from disposal of immovable property, permanent establishments, ships, aircraft, and shares</h1> Gains from disposal of immovable property may be taxed in the State where the property is located. Gains from disposal of movable property forming part of a permanent establishment or a fixed base in the other State, including disposal of that establishment or base, may be taxed in that other State. Gains from disposal of ships or aircraft used in international traffic and related movable property are taxable only in the State of which the enterprise is a resident. Gains on disposal of shares deriving more than 50% of their value from immovable property may be taxed where the property is situated; other share disposals are taxable in the company's State of residence. All other property gains are taxable only in the alienator's State of residence.
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