Capital Gains

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.... a permanent establishment which an enterprise of a Contracting State has in the other contracting State or of movable property pertaining to a fixed base available to a resident of a contracting State in the other contracting State for the purpose of performing independent personal services, including such gains from the alienation of such a permanent establishment (alone or with the whole enterp....

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.... other State (at the time of the alienation or at any time during the twelve preceding months); may be taxed in that other State.] 5. Gains derived by a resident of a contracting State from the sale, exchange or other disposition, directly or indirectly, or shares other than those mentioned in paragraph 4, or similar rights in a company which is a resident of the other contracting State may ....