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    <description>Capital gains are allocated by reference to property type and situs: gains from immovable property situated in the other Contracting State may be taxed there; gains from movable property of a permanent establishment or fixed base may be taxed in the State where that establishment or fixed base is located; gains from ships or aircraft in international traffic are taxable only in the alienator&#039;s State of residence; gains from shares of a resident company may be taxed in that State; other gains are taxable only in the alienator&#039;s State of residence. A multilateral rule allows taxation by the State where immovable property is located if shares derived more than 50% of their value from such property within 365 days before alienation.</description>
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