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    <title>Capital Gains</title>
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    <description>Article 13 allocates taxing rights for capital gains: gains from immovable property situated in the other Contracting State may be taxed in that State; gains of movable property forming part of a permanent establishment or fixed base, and gains from alienating such establishments or bases, may be taxed where they are situated; gains from ships, aircraft in international traffic, and their operational movable property are taxable only in the alienator&#039;s State of residence; transfers of shares deriving more than half their value from immovable property in the other State within the prior 365 days, and transfers of shares of a company resident in the other State, may be taxed in that other State; other gains are taxable only in the alienator&#039;s residence State.</description>
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      <title>Capital Gains</title>
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      <description>Article 13 allocates taxing rights for capital gains: gains from immovable property situated in the other Contracting State may be taxed in that State; gains of movable property forming part of a permanent establishment or fixed base, and gains from alienating such establishments or bases, may be taxed where they are situated; gains from ships, aircraft in international traffic, and their operational movable property are taxable only in the alienator&#039;s State of residence; transfers of shares deriving more than half their value from immovable property in the other State within the prior 365 days, and transfers of shares of a company resident in the other State, may be taxed in that other State; other gains are taxable only in the alienator&#039;s residence State.</description>
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