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of <h1>Gains from foreign immovable property and business assets taxable in their location; international transport gains taxed at residence.</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. Movable property gains tied to a business's permanent establishment or fixed base in the other State are also taxable there. Gains from ships or aircraft in international traffic are taxable only in the resident State. Gains from shares primarily consisting of immovable property in a Contracting State are taxable in that State, while other share gains are taxed in the resident State. Gains from other properties are taxable only in the alienator's resident State.
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