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    <title>Capital Gains</title>
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    <description>Article 13 allocates taxation of capital gains: immovable property situated in the other Contracting State may be taxed by that State; gains from movable property forming part of a permanent establishment or fixed base in the other State, including on alienation of that establishment or base, may be taxed by that State; gains from ships or aircraft in international traffic are taxable only in the alienator&#039;s State of residence; gains on shares of companies principally owning immovable property may be taxed in the State where that immovable property is situated; gains on other shares of a resident company may be taxed in the company&#039;s State of residence; other gains are taxable only in the alienator&#039;s State of residence.</description>
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      <description>Article 13 allocates taxation of capital gains: immovable property situated in the other Contracting State may be taxed by that State; gains from movable property forming part of a permanent establishment or fixed base in the other State, including on alienation of that establishment or base, may be taxed by that State; gains from ships or aircraft in international traffic are taxable only in the alienator&#039;s State of residence; gains on shares of companies principally owning immovable property may be taxed in the State where that immovable property is situated; gains on other shares of a resident company may be taxed in the company&#039;s State of residence; other gains are taxable only in the alienator&#039;s State of residence.</description>
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